Comment Log Display

COMMENTS OF THE CLIMATE SOLUTIONS GROUP LIMITED
ON 
CALIFORNIA CAP-AND-TRADE REGULATION AMENDMENTS 

The Climate Solutions Group Limited (CSG) is engaged in the
business of bringing capital to bear on activities that fight
climate change using the mechanisms created by the cap and trade (C
and T) laws of California, Quebec and now Ontario as well as the
offset creation and trading opportunities created in the Provinces
of Alberta and British Columbia. We hope to expand our operations
to other jurisdictions as similar systems and opportunities are
adopted/created.

Some of the principals of CSG have deep experience with emissions
trading in international markets, the existing WCI markets, the
Alberta and British Columbia markets and voluntary offset markets.
As such, we appreciate the consultation undertaken by the
California Air Resources Board (ARB) with respect to the existing
California C and T system. 

Our experience and analysis leads us to the conclusion that:

Offsets are an essential part of a C and T system and that the
creation and expanded use of offsets should be fostered by ARB. 

Offsets reach outside the covered sectors to find low cost
greenhouse gas (ghg) emission reductions that reduce the cost of
compliance for covered sectors and provide opportunities for
participation in the fight against climate change to economic and
other sectors (like forestry, agriculture, ranching and other
animal husbandry and chemical and organic waste management that
otherwise find participation challenging. Offset creation and use
engages with business training and capacities throughout the
economy and directs creative initiatives using those skills and
resources into enterprises that are intended to be profitable and
which are directed specifically to ghg emission reduction
activities. 

We strongly support the continuation of at least the current
permitted use and ability to create offsets but also the expansion
of the limit on emissions that can be covered with offsets to 20%
or more (from the current 8%) and of the number of science-based
and environmentally robust protocols for offset creation, for
example ,to be more in with Alberta where over 30 protocols are
available. 

We would be pleased to expand on our views and our role in
introducing capital into the C and T markets, particularly into
offset creation and use. 
Thank you for the opportunity to be heard. 

Yours sincerely,

Gray Taylor, General Counsel and Principal