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TransAlta believes that ARB should develop their cap and trade
program in a way that offers regulatory clarity and respects each
state’s own methods of transitioning to cleaner sources of energy. 
TransAlta encourages the California Air Resources Board to
implement regional default emission averages for electricity
imports.  TransAlta recognizes that this type of approach would
require a fundamental change to ARB regulations, which may not be
feasible before program implementation in 2013.  Therefore, until
such a time when this type of change in program design can occur,
TransAlta supports additional changes to the MRR that provide
clarity.  In particular, TransAlta supports WPTF’s recommendation
that ARB add a new definition of ‘specified power contract’ to the
MRR and use this term in operational provisions that apply to
specified imports.