Comment Log Display
Below is the comment you selected to display.
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
If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.