Comment Log Display

GPI is glad to see that ARB is incorporating cost containment
mechanisms within the Cap and Trade program.  Banking of
allowances, the three year compliance period, the allowance
reserve, and the use of offsets are important mechanisms for the
program.  We, however, remain concerned that the offset mechanism
is far too limited, as 51% reduction is anticipated to come from
onsite.   For CHP, this is a rule that drives facilities to
consider only big capital investments they can make in the turbine,
for example.  It locks out CHP from inexpensive investments they
could make to reduce GHG in other sectors.  For this reason, GPI
recommends that CHP be exempted from the 51% rule.  If this was
done, offsets would provide a significant mechanism, where projects
can be performed throughout the partner jurisdictions of WCI.