| 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.
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