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Comment 54 for Proposed Amendments to the Cap-and-Trade Program (cap-trade-draft-ws) - 1st Workshop.


First Name: Bill
Last Name: Buchan
Email Address: buchan@mktpotential.com
Affiliation: Cardinal Cogen, Inc.

Subject: Provide True-Up for Legacy Contract Allowances
Comment:
Legacy contract allowances for 2013 and 2014 are proposed to be
calculated based on 2012 data without a true-up.  True-up with
actual data is proposed in other parts of the regulation where
direct allowances are provided, and the same true-up protocol
should apply to legacy allowances as well.  For a number of
reasons, 2012 data may have little relevance to actual output in
2013 and 2014.  In the interest of fairness to legacy contract
parties, please provide a true-up for the allowance calculations in
95894(c) and (d).  

Attachment: www.arb.ca.gov/lists/com-attach/56-cap-trade-draft-ws-UzJdKQBjAg5SZgEx.docx

Original File Name: ARB 2013 cap and trade comment - Legacy allowance true-up.docx

Date and Time Comment Was Submitted: 2013-08-02 16:39:54



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