Proposed Amendments to the California Cap on Greenhouse Gas Emissions and Market- Based Compliance Mechanisms Regulation

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Comment From: Mary Elizabeth

5/28/26 @ 9:04 AM

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Comment From: CALCOG (Vincenzo Caporale)

5/28/26 @ 9:03 AM

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Comment From: Los Angeles Business Council (Clare Lethmon)

5/28/26 @ 9:00 AM

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Comment From: ClimateBuild California (Mikhael Skvarla)

5/04/26 @ 11:58 PM 15-1

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Comment From: Danny Cullenward

5/04/26 @ 11:40 PM 15-1

Please see attached file.

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Comment From: Pacific Gas & Electric (PG&E) (Fariya Ali)

5/04/26 @ 11:37 PM 15-1

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Comment From: New Forests (Will Collier)

5/04/26 @ 11:36 PM 15-1

Find attached New Forests' comments to the Proposed 15-Day Amendments.

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Comment From: Aclima, Inc. (Brian Crisp)

5/04/26 @ 11:09 PM 15-1

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Comment From: Clayton Munnings

5/04/26 @ 10:56 PM 15-1

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Comment From: CALSTART (Darryl Little)

5/04/26 @ 10:55 PM 15-1

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Comment From: San Diego Gas & Electric Compa... (Sarah Taheri)

5/04/26 @ 10:54 PM 15-1

Please find San Diego Gas & Electric Company's comments on the proposed 15-day amendments to Cap-and-Invest regulation attached. Thank you.

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Comment From: Karen Kirschling

5/04/26 @ 10:30 PM 15-1

The changes CARB has made to Cap and Trade fail to go far enough, and have gone in the wrong direction. You have been making changes that invest that money into massive giveaways to industry, rather than going towards credits on electricity bills or ...↓

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Comment From: Clean & Prosperous (Michael Ma... (Michael Mann)

5/04/26 @ 10:07 PM 15-1

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Comment From: Jennifer Jordan

5/04/26 @ 9:57 PM 15-1

California families are suffering economically due to over regulation by CARB.

I urge CARB to immediate pause any new changes to its CAP and Trade regulations. CARN must bring immediate cost and tax burden relief to California families and businesses...↓.

Thank you

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Comment From: Green Hydrogen Coalition (Tim Kamermayer)

5/04/26 @ 9:46 PM 15-1

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Comment From: Kern Energy (Melinda Palmer)

5/04/26 @ 9:37 PM 15-1

Please see Kern Energy's comments in the attached letter. Thank you.

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Comment From: Regulatory Flexibility Group (... (John Heintz)

5/04/26 @ 8:45 PM 15-1

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Comment From: Danielle Sells

5/04/26 @ 8:38 PM 15-1

Urgent Fixes Needed to Proposed 15-Day Cap-and-Invest Regulation Amendments

Dear CARB Staff and Board Members,

Californians are feeling the real impacts of climate disasters that are not just devastating our communities and lands, but also driving ...↓an affordability crisis. Families are bearing the costs of a warming climate through insurance premiums and utility bills, health expenses and hospital bills, higher prices on household goods, and are held hostage by Big Oil's price gouging at the pump. Cap-and-Invest is one of our state's biggest climate programs and is a critical source of funding for close to home community investments like transit, parks, clean cars, charging infrastructure, electrifying homes, and critical disaster response. The April proposal amending the program will slow our climate progress and gut the annual program revenue by $2 billion a year at a time when our state is cutting safety net services across the board for Californians.

The California Air Resources Board (CARB) must immediately amend the proposal to ensure that the Cap-and-Invest program will benefit Californians, not provide polluters with excessive handouts:
Eliminate the Manufacturing Decarbonization Incentive (MDI), which would provide incentives to industry while depressing the allowance auction revenue
Correct the bloated free allowance allocation by lowering the cap adjustment factor
Protect Cap-and-Invest revenues, rejecting any changes that would reduce funding and jeopardize investments that help Californians address climate-driven cost increases.
The consequences of this proposal to the program's Greenhouse Gas Reduction Fund (GGRF) are severe. This dwindling pot of money has invested billions of dollars in dozens of critical programs – clean vehicle access, safe and affordable drinking water, wildfire resiliency, and affordable housing. A failing program will decrease dollars for our state's environmental programs. Around nine billion dollars from this fund has already been invested in programs benefitting California's disadvantaged and low-income households, the "priority populations". This group is hit the hardest by the impacts of climate change and will be impacted the most by these programs going unfunded.

This proposal provides handouts to the oil and gas industry with no guarantee that fuel prices or emissions will go down. Californians would still be exposed to swings in the global oil market and the strong influence these corporations have in our state. While gas prices soar due to international supply shortages, oil companies are raking in record profits. Californians shouldn't be paying for subsidies to oil companies that don't bring prices down and take billions away from critical state funding.

At a time when California's leadership can provide a backstop against federal attacks and rising costs that are burdening families, we cannot afford to give corporate polluters more handouts. Now is the time for CARB to put Californians first.

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Comment From: Carbon Removal Organizations (Myron Lam)

5/04/26 @ 7:50 PM 15-1

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Comment From: Natural Gas Investor Owned Uti... (David Smith)

5/04/26 @ 7:41 PM 15-1

Please see the attached comments from the Natural Gas IOUs.

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Comment From: Third Way (Ryan Fitzpatrick)

5/04/26 @ 7:39 PM 15-1

May 4, 2026
Submitted via public comment process
California Air Resources Board
1001 I Street
Sacramento, CA 95814

Dear Chair Sanchez and Members of the Board:

On behalf of Third Way, I appreciate the opportunity to comment on the California Air R...↓

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Comment From: SoCalGas (David Smith)

5/04/26 @ 7:34 PM 15-1

Please see attached comment letter.

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Comment From: National Cement Company of Cal... (Jon Dearing)

5/04/26 @ 7:25 PM 15-1

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Comment From: American Farmland Trust (Chelsea Gazillo)

5/04/26 @ 7:25 PM 15-1

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Comment From: Ceres (Maggie Field)

5/04/26 @ 7:22 PM 15-1

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Comment From: Transit Agency Coalition (Michael Pimentel)

5/04/26 @ 7:02 PM 15-1

Submitted on behalf of a coalition of transit agencies and regional entities. This letter updates the previous letter we submitted on 4/30.

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Comment From: California Transit Association... (Michael Pimentel)

5/04/26 @ 6:59 PM 15-1

Submitted by the California Transit Association on behalf of the 67 organizations identified with logos and in the signature block. This letter updates the previous letter we submitted on 4/30.

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Comment From: California Environmental Voter... (Gracyna Mohabir)

5/04/26 @ 6:57 PM 15-1

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Comment From: Los Angeles Department of Wate... (Cindy Parsons)

5/04/26 @ 6:48 PM 15-1

See attached comment letter.

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Comment From: Senators Catherine Blakespear ... (Heather Walters)

5/04/26 @ 6:43 PM 15-1

Please see attached letter and supplemental questions from the Chairs of the Senate Environmental Quality Committee and the Senate Budget & Fiscal Review Subcommittee No. 2 on Resources, Environmental Protection and Energy.

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Comment From: Environmental Defense Fund (Caroline Jones)

5/04/26 @ 6:26 PM 15-1

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Comment From: Coalition for Sustainable Ceme... (Steve Coppinger)

5/04/26 @ 6:18 PM 15-1

I respectfully submit the attached comments on behalf of the Coalition for Sustainable Cement Manufacturing & Environment (CSCME).

Sincerely,
Steve Coppinger
Chair, Executive Committee

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Comment From: Sierra Business Council (Steven Frisch)

5/04/26 @ 6:14 PM 15-1

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Comment From: Climate Reality Project: Silic... (Ken Johnson)

5/04/26 @ 5:51 PM 15-1

My comments, attached herewith, reiterate concerns voiced by many stakeholders and the Legislature about the legality of CARB's proposed Build Up California Reserve, and identify several regulatory alternatives that would be responsive to industry in...↓

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Comment From: California Environmental Justi... (Matt Holmes)

5/04/26 @ 5:43 PM 15-1

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Comment From: Carbon Removal Organizations (Myron Lam)

5/04/26 @ 5:36 PM 15-1

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Comment From: The Nature Conservancy (Megan Cleveland)

5/04/26 @ 5:34 PM 15-1

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Comment From: Martha Fuchs

5/04/26 @ 5:28 PM 15-1

California Air Resources Board

I do NOT want you to increase the limits to cap and invest program.

I do NOT want the cost of gasoline to increase.

I do NOT want increased utility bills.

I do NOT want an increase to any fuel costs.

I do NOT want an increas...↓e to any energy costs.

I DO want you to drop the 2045 carbon neutrality goals.

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Comment From: Bret Andrews

5/04/26 @ 5:23 PM 15-1

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Comment From: 1PointFive (Jona Koka)

5/04/26 @ 5:21 PM 15-1

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Comment From: Sacramento Municipal Utility D... (Sara Christian)

5/04/26 @ 5:21 PM 15-1

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Comment From: Jeffrey Kilbreth

5/04/26 @ 5:06 PM 15-1

I live in Richmond, one of the first ten AB 617 communities. I live half a mile from the Chevron Richmond refinery and have served on our AB 617 Community Steering Committee for over 5 years. I care about reducing GHGs steadily in order to save the p...↓lanet and improving public health in industrial communities like my home town. I assume CARB cares about both of these things as well. My summary reactions to the proposed changes to CAP & Trade/Invest are as follows

1) I'm disappointed by the emissions reduction trajectory you propose, especially from 2031-2045. Getting back to where we were in 1990 by 2045 is simply not stepping up to the challenge. Why don't we shoot for something significantly lower than 1990 by 2045? I haven't seen anything that convinced me we couldn't achieve this. It certainly looks like China and Europe are going to achieve greater reductions than what you are proposing. Think bigger about massive increases in renewable electricity generation and all of the ways we can replace fossil fuels with clean electricity.

2) Household Energy Relief. The average household PG&E bill is probably now well over $3K per year and we all know that gasoline is up $1.50 per gallon with many households spending over $5K per year at current prices. The average household income in Richmond is around $60K, roughly 50% of the Contra Costa County average. Many households make $30-40K. What are you doing about this approaching crisis and the inequality of these impacts? I think an aggressive program to get money to the lower half of the income distribution is called for. Certainly CARB should champion using this fund for this purpose and if necessary take money out of "Invest" and put it into "Relief."

3) Climate Investment Fund. Many of the ideas here are good and are broadly part of an effective CAP & Trade/Invest program. In the big picture, we should provide incentives to electrify everything we reasonably can and speed up the percentage of renewable generation we have to work with. What we should be very wary of is industry ideas like "carbon sequestration & storage." Projects like the Montezuma Carbon Hub proposal are very risky in terms of cost overruns and poor ROI, unlikely to make that much of a difference in meeting our 2045 goals, and very likely to cause a lot of emissions and public health problems in the very industrial AB 617 communities we are supposed to be improving. This is simply not a place where we should be subsidizing industry. Put the money into getting to 90% renewable electricity by 2045 and ask the public and industry to "Go Electric wherever possible" Don't subsidize carbon sequestration & storage unless you can prove it makes economic sense and doesn't cause public health problems greater than the the tiny amount of GHGs that will be removed from the atmosphere.

4) Pay attention to what Chevron and the other refineries are saying about California being an energy island, market leakage, relative costs and necessary planning horizons for capital programs. I want Chevron to reduce GHG emissions wherever they can. And even more, I want them to reduce the 15-20 Toxic Air Contaminants that drive our health problems. But I don't want them to have unreasonable regulatory burdens and we can't forget that our economy still runs on gasoline, jet fuel and lubricants. We can hope we get to 90% renewable electricity and 80% electric cars, stoves, HVAC, and hot water heaters by 2045, but we'll still need some refineries. And we want them to be as well maintained as possible and to have the least possible impact on public health. We don't want to have to get our gas or jet fuel from China!

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Comment From: California Council for Environ... (Chris Shimoda)

5/04/26 @ 5:02 PM 15-1

Please see the attached comments of the California Council for Environmental and Economic Balance (CCEEB).

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Comment From: Western States Petroleum Assoc... (Jodie Muller)

5/04/26 @ 4:59 PM 15-1

Please see attached.

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Comment From: Sara Theiss

5/04/26 @ 4:57 PM 15-1 Form Letter 8

I live in Richmond, as does my husband who has COPD, my grandson who has asthma, and my son-in-law has diabetes. And of course, Richmond is home to the Chevron refinery. The proposed rules do very little or nothing to help my family members they appe...↓

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Comment From: Senator Brian W. Jones (Brian Jones)

5/04/26 @ 4:54 PM 15-1

Please see the attached letter from Senate Minority Leader Brian W. Jones.

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Comment From: California Resources Corporati... (Andrew Cochrane)

5/04/26 @ 4:44 PM 15-1

Please find attached California Resources Corporation's comments on the April 14, 2026 15-day modifications to the proposed amendments to the Cap-and-Invest Regulation and Mandatory Greenhouse Gas Emissions Reporting Regulation, submitted on behalf o...↓

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Comment From: PBF Energy Inc. (Rick Shih)

5/04/26 @ 4:44 PM 15-1

Please see attached comment letter. Thank you.

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Comment From: California Bioenergy LLC (Andrew Craig)

5/04/26 @ 4:42 PM 15-1

3950 K St.
Tulare, CA 93292
559-667-9560
May 4th, 2026
Mr. Matt Botill
Division Chief, Industrial Strategies
California Air Resources Board
1001 I Street
Sacramento, California 95814
Re: California Bioenergy's Comments on CARB's 2026 Proposed Amendme...↓nts to the Regulation for the California Cap on Greenhouse Gas Emissions and Market-Based Compliance Mechanisms
Dear Mr. Botill,
Thank you for the opportunity to provide these comments to California Air Resources Board (CARB) relating to the 15-day Proposed Amendments released on April 14th, 2026. California Bioenergy LLC (CalBio) is appreciative of CARB's efforts over the past several years to develop the Cap and Invest program into becoming one of the most impactful policies to support the reduction of statewide greenhouse gas emissions in line with statutory climate targets.
Founded in 2006, CalBio partners with California dairy farm families, dairy co-ops, CARB, the California Department of Food and Agriculture (CDFA), the California Public Utility Commission (CPUC), the California Energy Commission (CEC), and the U.S. Environmental Protection Agency (EPA). We exist to reduce methane emissions and are committed to enhancing environmental sustainability for all Californians. CalBio's digester projects produce renewable natural gas and electricity which support California's AB 32 and SB 1383 climate goals, displace fossil fuels, improve local air quality, and create jobs and investment in disadvantaged and dairy communities.
Revisions to Section 95852.1
The draft regulation as revised in the 15-day language proposes to modify the requirements for "biomass-derived" fuels to be claimed as exempt from incurring a compliance obligation (i.e., as set forth in proposed amendments to Section 95852.1). The revised language states that:
An entity has a compliance obligation for every metric ton of CO2e emissions from biomass-derived fuels as set forth in this subarticle, except for CO2 emissions from exempt biomass and exempt biomass-derived fuels. An entity claiming use of an exempt biomass-derived fuel must have sole ownership or contract rights to the biomass-derived fuel and any associated emissions exemption or emissions reductions attributed to the use of the fuel such that no other entity may claim an emissions exemption to reduce a compliance obligation in the Cap-and-Invest Program or in a linked external GHG emissions trading system."
CalBio appreciates these revisions that clarify and simplify this provision in the Cap-and-Invest regulation. We understand that the intent of this language is to ensure that only one entity is able to claim an exemption for the use of biomass-derived fuels under the Cap-and-Invest regulation. We also understand that this language does not preclude the producer of the fuel from seeking offset credits under a compliance offset protocol for emission reductions attributable to the feedstock. For example, it is our understanding that a dairy can develop an offset project for methane destruction derived from manure capture at the dairy and also sell the upgraded biogas to a covered entity which is ultimately used to claim an exemption from the Cap-and-Invest regulation. We would appreciate CARB's confirmation of this understanding in the Final Statement of Reasons.
Please do not hesitate to reach out if you have any questions.
Sincerely,
Andrew Craig
Vice President, Greenhouse Gas Programs
California Bioenergy LLC

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Comment From: California Chamber of Commerce (Jonathan Kendrick)

5/04/26 @ 4:39 PM 15-1

Attached please find the California Chamber of Commerce's Comments on the Proposed 15-Day Amendments to the California Cap on Greenhouse Gas Emissions and Market-Based Compliance Mechanisms Regulation.

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Comment From: California Environmental Voter... (Gracyna Mohabir)

5/04/26 @ 4:34 PM 15-1

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Comment From: California Carbon Solutions Co... (Virgil Welch)

5/04/26 @ 4:28 PM 15-1

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Comment From: Placer County Air Pollution Co... (Christiana Darlington)

5/04/26 @ 4:25 PM 15-1

Please see attached comment letter from Placer County Air Pollution Control District regarding Proposed Amendments to the California Cap on Greenhouse Gas Emissions and Market- Based Compliance Mechanisms Regulation.

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Comment From: Gwynne Gilson

5/04/26 @ 4:24 PM 15-1 Form Letter 8

I Support the following:

(1) Make the "cap" lower to lower emissions and meet California's climate goals;
(2) reduce giveaways to the oil and gas industry, especially by eliminating the new "manufacturing decarbonization incentive"; and
(3) increase...↓

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Comment From: State Building and Constructio... (Jeremy Smith)

5/04/26 @ 4:24 PM 15-1

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Comment From: California Hydrogen Coalition (Teresa Cooke)

5/04/26 @ 4:23 PM 15-1

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Comment From: BlueZone Health Solutions (Victor Tamashiro)

5/04/26 @ 4:21 PM 15-1 Form Letter 10

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Comment From: Allensworth Progressive Associ... (Denise Kadara)

5/04/26 @ 4:20 PM 15-1

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Comment From: California Hydrogen Business C... (Katrina Fritz)

5/04/26 @ 4:20 PM 15-1

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Comment From: UPAAGLA (Annie Nepomuceno)

5/04/26 @ 4:19 PM 15-1 Form Letter 10

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Comment From: Constellation Energy Generatio... (Diana Gallegos)

5/04/26 @ 4:19 PM 15-1

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Comment From: Small Business Development Cor... (Mike Ocasio)

5/04/26 @ 4:18 PM 15-1 Form Letter 10

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Comment From: Fresno Business Council (Kendra Devejian)

5/04/26 @ 4:17 PM 15-1 Form Letter 10

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Comment From: Middle Eastern and North Ameri... (Mike Aqrawi)

5/04/26 @ 4:16 PM 15-1 Form Letter 10

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Comment From: South Asian Biz Alliance Netwo... (Mohammed Islam)

5/04/26 @ 4:14 PM 15-1 Form Letter 10

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Comment From: Filipino American Chamber of C... (Femie Cupit)

5/04/26 @ 4:14 PM 15-1 Form Letter 10

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Comment From: Filipino American Chamber of C... (Ruth Canlobo)

5/04/26 @ 4:12 PM 15-1 Form Letter 10

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Comment From: Filipino American Chamber of C... (Ellen Rodriguez-Swing)

5/04/26 @ 4:11 PM 15-1 Form Letter 10

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Comment From: Coalition of Filipino American... (Garry Palon)

5/04/26 @ 4:09 PM 15-1 Form Letter 10

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Comment From: Regional Cal Black Chamber (MC MC Townsend)

5/04/26 @ 4:08 PM 15-1 Form Letter 10

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Comment From: CalAsian Chamber of Commerce (Jazmine Advincula)

5/04/26 @ 4:06 PM 15-1 Form Letter 10

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Comment From: California Hispanic Chamber of... (Julian Canete)

5/04/26 @ 4:05 PM 15-1

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Comment From: California Municipal Utilities... (Derek Dolfie)

5/04/26 @ 4:04 PM 15-1

Please see the attached response comment letter from the California Municipal Utilities Association (CMUA) and the Golden State Power Cooperative (GSPC) on the 15-day changes to the Cap-and-Invest regulations.

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Comment From: Coalition of Environmental, En... (Chloe Ames)

5/04/26 @ 3:57 PM 15-1

Dear Chair Sanchez and CARB staff,

On behalf of 45 groups with expertise on environmental, environmental justice, public transit, public health, and agricultural topics, we submit the following coalition letter expressing significant climate and af...↓

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Comment From: California Manufacturers and T... (Elizabeth Esquivel)

5/04/26 @ 3:52 PM 15-1

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Comment From: League of California Cities & ... (Melissa Sparks-Kranz)

5/04/26 @ 3:51 PM 15-1

May 4, 2026 Comments transmitted via CARB
Public Comment Portal
Ms. Lauren Sanchez
Chair, California Air Resources Control Board
1001 I Street
Sacramento, CA 95814

RE: Public Comments - Proposed Amendments to the California Cap on Greenhouse Gas ...↓

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Comment From: Blue Planet (Kevin Davis)

5/04/26 @ 3:50 PM 15-1

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Comment From: Sierra Harvest (Lindsey Pratt)

5/04/26 @ 3:36 PM 15-1

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Comment From: Center for Food Safety (Kristina Sinclair)

5/04/26 @ 3:35 PM 15-1

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Comment From: California Independent System ... (Sarah Kozal)

5/04/26 @ 3:35 PM 15-1

Attached are the comments of the California Independent System Operator Corporation on the modifications to the proposed amendments to the California Air Resources Board's regulations related to the California Cap on Greenhouse Gas Emissions and Mark...↓

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Comment From: Food Access LA (Jennifer Grissom)

5/04/26 @ 3:32 PM 15-1

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Comment From: ValleyCAN (Scott Cox)

5/04/26 @ 3:31 PM 15-1

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Comment From: Environmental Justice Coalitio... (Lauren Gallagher (CBE) )

5/04/26 @ 3:27 PM 15-1

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Comment From: Alliance for Retail Energy Mar... (Andrew Brown)

5/04/26 @ 3:19 PM 15-1

Please see Comments of the Alliance for Retail Energy Markets on the 15-Day Proposed Amendments to the Cap-and-Invest Regulation attached. Thank you.

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Comment From: California Forest Carbon Coali... (Mikhael Skvarla)

5/04/26 @ 3:18 PM 15-1

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Comment From: The Electric Vehicle Charging ... (Scott Cox)

5/04/26 @ 3:17 PM 15-1

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Comment From: California Community Choice As... (Shawn-Dai Linderman)

5/04/26 @ 3:13 PM 15-1

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Comment From: Dairy Cares (Michael Boccadoro)

5/04/26 @ 3:11 PM 15-1

Please see Dairy Cares comments on the 15-day Proposed Amendments to the Cap-and-Invest Regulation attached. Thank you!

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Comment From: Trust for Public Land (Juan Altamirano)

5/04/26 @ 3:07 PM 15-1

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Comment From: Lisa Bain

5/04/26 @ 3:02 PM 15-1

Dear CARB Staff and Board Members,

As a public health professional who has spent the past 15 years focused on infant mortality prevention, I am deeply concerned about proposed changes to California's Cap and Invest program that would weaken protect...↓

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Comment From: VERA (Jon Costantino)

5/04/26 @ 2:58 PM 15-1

VERA comments attached.

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Comment From: Pa Houa Lee

5/04/26 @ 2:52 PM 15-1

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Comment From: Charm Industrial (Nora Cohen Brown)

5/04/26 @ 2:50 PM 15-1

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Comment From: Nucor (Amari Jones Scriven)

5/04/26 @ 2:42 PM 15-1

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Comment From: Jean-Luc Szpakowski

5/04/26 @ 2:41 PM 15-1

With climate change accelerating with the hottest March on record, the Air resource board needs to reduce the amount of greenhouse gases it permits. This shoud be a hard cap., resources should be spent on renewable energy nad battery storage, not w...↓