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Comment 58 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: Legacy Allowance for 1st Compliance Period
Comment:
Legacy contract allowances are proposed to receive 2015 vintage
allowances for the 2013-14 compliance period.   Asking our 3rd
party CHP to float the cost of compliance before receiving state
compensation is a real and unnecessary cost to our facility.  These
allowances should be allowed for use is settling the 2013-14
compliance requirements.  Unfortunately, the draft regulation under
95856 (h)(1)(c) and (2)(c) do not yet allow this.   

Attachment: www.arb.ca.gov/lists/com-attach/60-cap-trade-draft-ws-VjdcKFY1UV1RZVJi.docx

Original File Name: ARB 2013 cap and trade comment - Legacy allowance for first compiance period.docx

Date and Time Comment Was Submitted: 2013-08-02 16:52:35



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