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Full picture on cutting emissions

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Re “Deregulation deja vu,” editorial, March 10

Your editorial about the California Public Utilities Commission’s recommendations to reduce greenhouse gas emissions overlooks several issues.

Assembly Bill 32 requires the Air Resources Board to address emissions from power plants in California and from the 20% to 25% of imported energy, which produces more than 50% of emissions. The first-deliverer approach makes sense because it places the regulatory obligation close to the source.

You also ignore the fact that over half of emissions from imported energy comes from five coal-fired plants that provide energy to several Southern California utilities. For the dirtiest imported power there is no middle man -- the first deliverer is the same entity that owns the plant or holds a contract for its output.

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A carbon tax offers no improvement in tracking imported emissions and would not be any less vulnerable to lobbying than a cap-and-trade system, which combined with California’s energy efficiency and renewables programs can help achieve the bill’s ambitious targets at the lowest cost.

Nancy Ryan

San Francisco

The writer is chief of staff to President Michael R. Peevey of the California Public Utilities Commission.

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