| Comment | I want to thank you for your work to put a cap on Greenhouse Gas
Emissions. I am strongly in favor of the cap and trade regulation
currently before the Board.
I am pleased to see that the proposed regulation includes the
following:
Fully auctioning allowances in the transportation sector
Strong enforcement
$10 per allowance price floor,
Additional ideas:
Maximize the use of auctioning as a method of allocating
allowances.
The level of free allocation proposed in the draft cap and trade
rule is a gift to Industry at Taxpayer expense.
CARB should clearly state in the regulation that it intends to move
toward 100 percent auctioning, and leave an opening to do so.
Ensure that Offsets Cannot Be Sold More than Once through Different
Registries
Lower the Offset Limit
Promote investment in Cost-Effective Energy Efficiency by requiring
Utilities that use allowance values for clean energy investments
should be required to first invest in cost-effective energy
efficiency.
Thank you,
Gil Varon
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