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November 5, 2007

Ms. Jennifer Davis
Budget Director
Governors Office of the Budget
540 S. DuPont Highway, Suite 5
Dover, DE  19901

Mr. Michael T. Scuse
Secretary
Delaware Department of Agriculture
2320 South DuPont Highway
Dover, DE 19901

Re:  DDA FY09 Budget Hearing Comments from The Nature Conservancy
      
Dear Secretary Scuse and Ms. Davis:

Thank you for the opportunity to submit written comments on behalf of The Nature Conservancy with respect to the Delaware Department of Agriculture’s (DDA) proposed FY09 budget.  We would appreciate your consideration of one funding items outlined below as you prepare for the Governor’s budget submission to the General Assembly.  

Program Priorities & Recommended Funding Levels

Regional Green House Gas Legislation – Allocation of CO2 Allowances

The Delaware Chapter of The Nature Conservancy strongly encourages Governor Minner and the 145th General Assembly to adopt Regional Greenhouse Gas legislation in Delaware during the upcoming legislation.  This bill represents our top legislative priority and also has implications for creating a new revenue stream to the state.  In adopting this legislation, we encourage inclusion of the following provisions: 
 
- A 100 percent auction of RGGI allowances under which the majority of allowance auction proceeds would fund energy efficiency and conservation and renewable energy development.
 
- Investing up to 10 percent of allowance auction revenues for climate change adaptation projects.   This might include modeling and mapping sea and Delaware Bay water-level rise and identification of habitat migration zones, forestland and coastal land preservation, ecological management in anticipation of climate change impacts such as sea-level rise, and integration of climate change into state Comprehensive Wildlife Conservation Strategies.
 
- The Conservancy supports expanding the types of offsets that sources can use to meet the emissions limits to include sustainable forest management and conservation.

Delaware could generate annual revenues of $3.8M to $75.6M through auction of credits depending on the percentage allocation and price per ton of CO2 equivalents.

The Nature Conservancy strongly supports allocation of a portion of the 10 percent of allowance auction revenues referenced above to create a permanent stream of funding for the Delaware Forestland Preservation Program.  This program was funded last year through in Governor Minner’s FY08 budget request at $1 million.  We encourage that up to $5 million of CO2 auction revenue be used to fund the Forestland Preservation Program annually.

Thank you for your consideration of our recommendations.

Sincerely,                             

Roger L. Jones, Jr.
Vice-President and State Director

cc:  Mr. John Hughes, Secretary, Delaware Dept. of Natural Resources & Environmental Control