Comment Log Display

The Compliance Offset Developers Association (CODA) appreciates the
opportunity to comment on the proposed updates to the Compliance
Offset Protocols - specifically for Livestock Projects - as
incorporated by reference in the proposed amendments to the
California Cap-and-Trade Regulation as described in the draft dated
July 29, 2014.

CODA is an association comprised of six of the leading developers
of emission reduction projects designed for compliance in the
California Cap-and-Trade program.  CODA’s membership has
substantial experience in the implementation of projects designed
to result in emission reduction offsets, and represents a majority
of the projects listed as ARB-Early Action projects or ARB
Compliance Projects.  

Our comments are based on practical experience over the last five
years in working to generate and qualify offsets from the project
types included in ARBs program. Incorporating them would provide
OPOs/APDs with greater clarity on how they should monitor and
operate projects and remove unnecessary cost and complexity without
compromising environmental integrity.

Please see the attached file for CODA's comments on the proposed
updates to the protocol for Livestock Projects.