First Name | Josh |
---|---|
Last Name | Margolis |
Email Address | jmargolis@cantorco2e.com |
Affiliation | CantorCO2e |
Subject | Cap and Trade Regulations |
Comment | It is recommended that CARB: 1. Eliminate buyer liability associated with offset reversals. 2. Eliminate the 8% cap on offset use for facility compliance. 3. Provide for the ability to carry forward/bank unused annual offset capacity. 4. Provide for the ability to use allowances and credits that result from shutdowns or curtailments. 5. Allocate allowances without charge throughout the duration of the program. The implementation of these recommendations will: 1. Improve the prospects for achieving the ambitious goals of the AB 32. 2. Minimize compliance costs. 3. Reduce the likelihood of leakage. 4. Foster a more robust liquid emissions market. |
Attachment | www.arb.ca.gov/lists/capandtrade10/1129-cantorco2e_cap_and_trade_comments_final_dec_15_2010.pdf |
Original File Name | CantorCO2e Cap and Trade comments final Dec 15 2010.pdf |
Date and Time Comment Was Submitted | 2010-12-15 10:25:39 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.