Comments in response to the October 21, 2016 California Cap-and-Trade Regulation Amendments Workshop

CRS comments regarding potential 2016 amendments to the California Cap-and-Trade Regulation discussed at the workshop held on October 21, 2016. Comments focus on post-2020 allowance allocation to Electrical Distribution Utilities (EDUs) and, in particular, on Staff’s most recent proposal regarding the RPS Adjustment, included in the Post-2020 Electrical Distribution Utility Allocation Informal Proposal. Comments also provide a recommendation for how to administer the RPS Adjustment and avoid double counting with directly delivered renewable energy.