Comment Log Display

Wildflower Energy, LP ("Wildflower") provides these comments on the
investment of cap-and-trade auction proceeds and in response to the
May 24, 2012 public consultation meeting.   Wildflower encourages
CARB to utilize a small portion of the auction proceeds to address
pre-AB 32 long-term power sales contracts that do not include
provisions allowing the project to recover the new greenhouse gas
("GHG") compliance costs within the contract structure and also
have no near-term access to markets in which the GHG compliance
costs might be recovered ("Pre-AB 32 Projects").  Wildflower owns
Pre-AB 32 Projects, which entered into long-term contracts to
stabilize the California electric market in 2001 and 2004.  These
Pre-AB 32 Projects may suffer a potentially devastating penalty for
their commitment to long-term contracts and stable pricing.  While
the "Pre-AB 32 Contract" issue is recognized by both the CPUC and
CARB, the issue remains unresolved.  As discussed below, a small
set-aside of allowance revenue to address this issue would further
the purposes of AB 32 by ensuring equity and minimizing the costs
of the program.

Original File Name: 120622 WFE Letter to ARB re cap-and-trade revenue (00075522).PDF

Date and Time Comment Was Submitted: 2012-06-22 11:37:31