Comment Log Display
Below is the comment you selected to display.
Comment 56 for Proposed Amendments to the Cap-and-Trade Program (cap-trade-draft-ws) - 1st Workshop.
First Name: Bill
Last Name: Buchan
Email Address: buchan@mktpotential.com
Affiliation: Cardinal Cogen, Inc.
Subject: Sunset on Legacy Allowance Provision
Comment:
Legacy contract allowances are proposed for 2013 and 2014, but not beyond even though many legacy contract extend well beyond 2014. While we understand that ARB would like to continue to encourage negotiating as a means of settling legacy contracts, the negotiating position for involved parties will not change (with possible exception of those involving universities who are covered entities). For Cardinal Cogen, our contract host is not a covered entity, so the negotiating position will be no different now than it will be in 2014. Expecting a renegotiation between now and then is not realistic, as our contract host has no reason to accept additional fees for greenhouse gases. We ask that the ARB reconsider the limitation on legacy allowances with the realization that ARB will be supporting CHP as enumerated in state policy knowing we had no way of foreseeing greenhouse gas costs at the time the contract was entered into.
Attachment: www.arb.ca.gov/lists/com-attach/58-cap-trade-draft-ws-VjdTJ1U2Ul4BNQEx.docx
Original File Name: ARB 2013 cap and trade comment - Legacy allowance sunset.docx
Date and Time Comment Was Submitted: 2013-08-02 16:49:53
If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.
