| First Name | Josh |
|---|---|
| Last Name | Margolis |
| Email Address | jmargolis@bgcpartners.com |
| Affiliation | BGC Environmental Brokerage Services, LP |
| Subject | Cap and Trade 2nd 15 Day Rule Package (v3) |
| Comment | 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 September 12, 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. |
| Attachment | www.arb.ca.gov/lists/capandtrade10/1689-bgcpartners_15_day_rule_change_comments_september_27_2011_v3.pdf |
| Original File Name | BGCPartners_15_Day_Rule_Change_Comments_September 27_2011 v3.pdf |
| Date and Time Comment Was Submitted | 2011-09-27 16:51:28 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.