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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.