Comment Log Display

The University of California (UC) support s the California Air
Resources Board’s (CARB) staff proposal to provide transition
assistance through the allocate allowances to universities.  If
adopted in its current form the regulatory amendments will relieve
UC approximately $8 million per year in cap and trade fees and
allow it to continue to invest in greenhouse gas reducing projects
across its campuses.
   
Under the proposal, universities would receive an allocation based
on the average emissions during 2008-2010 from each of its
facilities regulated under the cap and trade program.  The
allocation would then be reduced each year, keeping in line with
the same allowance reduction in the overall cap and trade program. 
UC believes this is a fair and equitable solution to the directive
given to CARB staff by its board (Resolution 12-33, September 20,
2012).
  
Nevertheless, UC is concerned about clarity regarding incorporating
the future growth of its facilities that are not currently
obligated under the cap and trade program.  Several of its campuses
are under the 25,000 mtCO2e threshold, but expect to surpass it as
they fulfill their educational and research mandates.  During the
workshop CARB staff also expressed these concerns and proposed
having the other facilities opt-in so that they would be eligible
to receive an allocation.  UC supports this solution, but requests
the regulations state a defined period of time after adopting the
new regulations that the campuses can decide to opt-in, or not, to
the cap and trade program to receive the allocation for transition
assistance.  The additional language will assure UC will not have
to opt-in facilities prior the regulations receiving final Board
approval. 

UC welcomes the allocation methodology proposed by CARB staff.  UC
believes the transition assistance will aid in its ability to
continue to reduce its greenhouse gas emissions to the benefit of
California and it looks forward to continue working with CARB staff
on the final proposed regulatory language.