First Name | Jackie |
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Last Name | Ferlita |
Email Address | jferlita@elementmarkets.com |
Affiliation | Element Markets |
Subject | Use of "True-Up" Allowances |
Comment | Dear ARB Staff: There seems to be some ambiguity around which vintage compliance instruments may be retired for annual and triennial compliance in the draft regulations. In the draft regulations section 95856(h)(1)(d) and (h)(2)(d), it appears to state that t-2 (“true-up”) allowances [allocated to account for changes in production and not properly accounted] are allowed to be used for (the current year’s) compliance obligation. In the draft regulations, it is not clear whether “true-up” allowances provided in future years (post-2015) will also be usable in the same way for the current year’s compliance obligation. Could you please clarify whether the same will be true for t-2 allowances in future years? For example, are true-up allowances that are allocated in the form of vintage 2018s for a calendar year 2016 increase in production valid to be used for an entity’s 2016 compliance obligation? Sincerely, Jackie Ferlita Director Element Markets |
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Date and Time Comment Was Submitted | 2013-10-22 10:43:40 |
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