First Name | Josh |
---|---|
Last Name | Margolis |
Email Address | jmargolis@cantorco2e.com |
Affiliation | CantorCO2e, LP |
Subject | Cap and Trade 15 day modifications to proposed regulations |
Comment | The attached letter provides comments on the California Air Resources Board’s (CARB) Proposed 15-Day Modifications to the Regulation for California Cap on Greenhouse Gas Emissions and Market-based Compliance Mechanisms (Cap and Trade Regulation) dated July 25, 2011. In summary, we recommend CARB: 1. Assign offset liability to those that are best able to manage it – the project developer and CARB 2. Increase the 8% offset limit 3. Allow for the forward carry of unused offset capacity 4. Issue multi-year allocations 5. Allow for the use of shutdowns/curtailment to generate credits The implementation of these recommendations will: • Improve the prospects for achieving the ambitious emission reduction goals of AB 32. • Minimize compliance costs. • Reduce the likelihood of leakage. • Foster a more robust liquid emissions market that improves compliance and reductions. Please see the attached letter for further detail. |
Attachment | www.arb.ca.gov/lists/capandtrade10/1394-cantorco2e_15_day_rule_change_comments_august_10_2011.pdf |
Original File Name | CantorCO2e_15_Day_Rule_Change_Comments_August_10_2011.pdf |
Date and Time Comment Was Submitted | 2011-08-10 21:53:37 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.