| First Name | Douglas |
|---|---|
| Last Name | Davie |
| Email Address | ddavie@wellhead.com |
| Affiliation | Wellhead Electric Company, Inc. |
| Subject | Comments on May 9, 2012 Notice of Amendments to Cap-and-Trade Regulation |
| Comment | Wellhead Electric Company, Inc. submits these comments to address the deletion of the Beneficial Holding Relationship provision (Section 95834) and the need for CARB to continue to evaluate and prepare for resolution of the issues faced by a very limited class of generators with pre-AB 32 contracts that have no available mechanism for recovery of AB 32 compliance costs. Wellhead suggests two regulatory amendments that will provide the CPUC and the CARB flexibility needed to address the matter should bilateral negotiations be unsuccessful. First, the CPUC should have the flexibility to not only create rules for revenue allocation, but also be able to adjust the disposition of allowances to utilities within its jurisdiction under a very limited set of circumstances. Second, CARB should enable the CARB Executive Director to adjust allowance allocations when an allocation to a utility fails to comport with Board intent and policy. |
| Attachment | www.arb.ca.gov/lists/capandtrade2012/25-120627_wellhead_comments_on_5.9.12_cap-and-trade_notice_vfin__00076417_.pdf |
| Original File Name | 120627_Wellhead Comments on 5.9.12 Cap-and-trade notice_VFIN (00076417).PDF |
| Date and Time Comment Was Submitted | 2012-06-27 11:20:51 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.