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The attached letter provides comments on the California Air
Resources Board’s (CARB) Proposed 15-Day Modifications to the
Regulation for California Cap on Greenhouse Gas Emissions and
Market-based Compliance Mechanisms (Cap and Trade Regulation) dated
July 25, 2011.  In summary, we recommend CARB:

1.	Assign offset liability to those that are best able to manage it
– the project developer and CARB
2.	Increase the 8% offset limit
3.	Allow for the forward carry of unused offset capacity
4.	Issue multi-year allocations
5.	Allow for the use of shutdowns/curtailment to generate credits
 
The implementation of these recommendations will:

•	Improve the prospects for achieving the ambitious emission
reduction goals of AB 32. 
•	Minimize compliance costs.
•	Reduce the likelihood of leakage.
•	Foster a more robust liquid emissions market that improves
compliance and reductions.

Please see the attached letter for further detail.