Letter from CRS to Kevin Kennedy, CARB Office of Climate Change on how to distribute allowances under a CA C&T program

This letter expresses CRS’s view on off-the top as well as other allocation issues. We express our view that CARB’s proposed approach to allowance distribution would be an unfortunate overreaction to emission leakage concerns, and resulting overcompensation of carbon emitters would represent a lost opportunity to bolster the emerging clean energy economy that can contribute badly needed new jobs.