Public Comment on Draft Climate Action Plan

The Alaska Center supports the work of the Climate Action Leadership Team and appreciates the effort of Governor Walker and Lt. Governor Mallott to initiate an Alaska-specific approach to climate change adaptation and mitigation. We appreciate the values statement in the Draft Climate Action Plan, specifically the goal for the state to “use values of equity, inclusion and justice, science and technology, cost effectiveness, market-based solutions and public engagement.” These values are critical in bringing all Alaskans to the table on the issue of climate change.

The Alaska Center is a statewide non-profit that engages and empowers Alaskans to advocate for clean air and water, healthy communities, and a strong democracy. We are working to make our home the best place to live and raise a family by engaging in the issues that resonate with a broad base of Alaskans and can build a more powerful movement for social and environmental change.

Alaska plays a key role in a broader national narrative on climate change. Alaska has captured the nation’s imagination and attention for decades, given our distance, climate, cultures, creatures, and lifestyles. As we are quickly being rendered by the impacts of climate change, Alaskans have the platform and responsibility to show the rest of the nation that we are stepping up to create long term clean energy prosperity. Establishing a strong Climate Action Plan is a step in the right direction.

We suggest that the final report include a plan of immediate action in the 2019-2020 Alaska State Legislature as a roadmap to achieve policy changes in the near term. The Climate Action Leadership Team is obviously a politically vulnerable ensemble and should use the time and mandate it has in 2018 to set up a specific course of action for future legislatures and administrations to consider.

In addition to the Goals and Objectives section of the Climate Action Plan, a “Strategy to Achieve Goals” section should be added and updated annually as long as the leadership team is operational. This addendum should include all legislative and administrative policy proposals that the Leadership Team agrees would advance goals set by the Climate Action Plan.

An omnibus or suite of legislation to be introduced in the 2019 legislative session can and should be described in a potential “strategy” section to a Climate Action Plan. This discussion draft would benefit from public review and comment prior to official introduction. This approach will promote transparency, civic engagement, and accountability with the specific policy agenda drafted by the Climate Action Leadership Team.

We agree with Lt. Governor Mallott that the conversation on climate change will and must be ongoing, and that we do not benefit from “crisis thinking” on climate change. However, we believe that the best role of this current Climate Action Leadership Team is to promote immediate action by discussing and introducing legislative and regulatory approaches, and municipal ordinances, allowing for public review and comment, and preparing for a major climate change policy push in 2019.

The Alaska Center supports the goal of 50% renewable generation statewide in all sectors by 2025 and believes that this can be achieved. We additionally support a goal of 100% renewable generation by 2050, and believe that planning for a 100% goal will be critical in achieving a 50% target in the near term.

We suggest adding a fiscal plan for Alaska, including new revenue generation and a rationalization of our petroleum taxation system, as well as specific measures to protect salmon habitat from increased impacts associated with large scale development projects to the draft goals and objectives statement.

A fiscal plan including an income tax on residents and non-residents, and significant changes to our oil production tax system is fundamental to any efforts to address and respond to climate change. Without the ability to pay for adaptation and mitigation efforts, Alaska will be reliant on fluctuating federal disaster funds, and as such will be in a constant competition with other jurisdictions in the United States that are also experiencing the effects of destructive weather and disasters. To assert home-grown leadership on climate change, Alaska must adopt a fiscal mechanism to help pay for it.

In regard to Draft Goal 5.3 “The State of Alaska will develop a pathway to a carbon pricing mechanism”, we suggest that the title of this goal would be strengthened by deleting “a pathway to”. We also suggest that this goal should be one of the Team’s top priorities. Like a fiscal plan for Alaska, some form of carbon pricing in Alaska is necessary and fundamental to address the challenges of climate change, and to help move Alaska toward a less carbon intensive economy. Without a mechanism to put a cost on the carbon pollution that is causing climate change we allow our atmosphere to be a rent-free dumping ground for pollution.

Draft Objective 5.3 b “Incentivize responsible, efficient and cleaner oil and natural gas development to support continued private investment and a clean energy transition.” This objective appears to point toward the need for an additional production tax decrease for North Slope oil and natural gas. Alaska presently owes nearly $1 billion to oil and gas companies due to tax incentives, and the current production tax system allows some companies to pay a minimum 4% tax, depriving Alaska of essential revenues. The Climate Action Leadership Team should carefully consider the use of the word “incentivize” in the context of oil development at this time. The use of “incentivize” in this context, and not in other goals within the plan, appears to indicate that the petroleum industry requires further financial concessions from the state in order to participate in climate change mitigation efforts. We suggest changing the word “incentivize” to “Require”.

Draft Goal 4.1 “The State of Alaska will reduce the impacts from climate change on Alaska’s natural environment and ecosystem, including food and water.” This goal should be bolstered to include specific changes that could strengthen protections of our environments and habitats, and our food and water security in Alaska. For example, House Bill 199, introduced in the 30th Alaska Legislature, as well as a subsequent ballot proposition, were and are designed to achieve new protections for the aquatic and riparian habitat that generates our salmon resource.

Climate change could devastate our salmon runs through ocean acidification, stream warming, and changes to seasonal weather cycles. Developmental impacts in salmon habitat provide additional stressors on our already threatened salmon populations. These impacts can be moderated and avoided by strengthening our laws that pertain to salmon habitat. We suggest that Draft Goal 4.1 should include an Objective supporting stronger statutory protections for our fisheries.

The Alaska Center believes that the Climate Action Leadership Team has an opportunity this year to put forward strong recommendations in its final report, and we support this effort to create an innovative and historic plan of action for the 2019 Legislative Session.

Thank you for your work and this opportunity to engage and hear from our communities statewide.

The Alaska Center

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