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Dear ARB Staff:

There seems to be some ambiguity around which vintage compliance
instruments may be retired for annual and triennial compliance in
the draft regulations.  

In the draft regulations section 95856(h)(1)(d) and (h)(2)(d), it
appears to state that t-2 (“true-up”) allowances [allocated to
account for changes in production and not properly accounted] are
allowed to be used for (the current year’s) compliance obligation. 


In the draft regulations, it is not clear whether “true-up”
allowances provided in future years (post-2015) will also be usable
in the same way for the current year’s compliance obligation.

Could you please clarify whether the same will be true for t-2
allowances in future years? For example, are true-up allowances
that are allocated in the form of vintage 2018s for a calendar year
2016 increase in production valid to be used for an entity’s 2016
compliance obligation?  

Sincerely,


Jackie Ferlita
Director
Element Markets