| Comment | Wellhead Electric Company, Inc. submits these comments to address
the deletion of the Beneficial Holding Relationship provision
(Section 95834) and the need for CARB to continue to evaluate and
prepare for resolution of the issues faced by a very limited class
of generators with pre-AB 32 contracts that have no available
mechanism for recovery of AB 32 compliance costs. Wellhead
suggests two regulatory amendments that will provide the CPUC and
the CARB flexibility needed to address the matter should bilateral
negotiations be unsuccessful. First, the CPUC should have the
flexibility to not only create rules for revenue allocation, but
also be able to adjust the disposition of allowances to utilities
within its jurisdiction under a very limited set of circumstances.
Second, CARB should enable the CARB Executive Director to adjust
allowance allocations when an allocation to a utility fails to
comport with Board intent and policy.
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