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The 4% limit of offsets on emissions is too low.  After reviewing
ARB's algorithm for coming up with the 4% limit, it is clear that
calculation is dependent on the use of offsets, assuming that most
if not all facilities will use offsets to the allowable limit. 
This is most likely not the case, and we encourage ARB to factor in
the degree of non-participating facilities in the offset program
when setting the offset limit.  Otherwise, the offset limit will be
overly restrictive as compared to the 49% goal set out in the
scoping plan.  Recommend increasing this limit to at least 8% of
total emissions to account for this and allow for sizeable
projects.