Letter on Recognizing Voluntary Early Actions in Cap-and-Trade

Commenting on issues relating to voluntary early emissions reductions in a California cap-and-trade program and CARB’s efforts in designing an effective cap-and-trade program as part of AB32. Recommending auction allowances to incentivize early action, carving out early action allowances from within the cap, maintaining distinction between capped sources and uncapped sources, ensuring reductions occur before 2012, incentivizing air quality and public health co-benefits, and “keeping it simple.”