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

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Comment From: Philip Conrad

3/04/26 @ 7:13 PM Form Letter 1

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Comment From: Philip Conrad

3/04/26 @ 6:51 PM Form Letter 1

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Comment From: Philip Conrad

3/04/26 @ 6:50 PM Form Letter 1

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Comment From: Philip Conrad

3/04/26 @ 6:48 PM Form Letter 1

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Comment From: Mike Collier

3/04/26 @ 6:46 PM

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Comment From: Corinne Cochran

3/04/26 @ 6:43 PM Form Letter 1

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Comment From: John Clements

3/04/26 @ 6:40 PM Form Letter 1

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Comment From: Alan D. Clark

3/04/26 @ 6:37 PM Form Letter 1

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Comment From: Armand Chevalier

3/04/26 @ 6:32 PM Form Letter 1

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Comment From: Thomas Brest

3/04/26 @ 1:25 PM Form Letter 1

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Comment From: Joe Campos

3/04/26 @ 1:14 PM Form Letter 1

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Comment From: Wayne Camara

3/04/26 @ 1:11 PM Form Letter 1

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Comment From: Norma Camacena

3/04/26 @ 1:08 PM Form Letter 1

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Comment From: Robert Callahan

3/04/26 @ 1:05 PM Form Letter 1

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Comment From: Aristides Caldevilla

3/04/26 @ 1:02 PM Form Letter 1

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Comment From: James Burstedt

3/04/26 @ 12:58 PM Form Letter 1

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Comment From: Bradley Buenger

3/04/26 @ 12:54 PM Form Letter 1

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Comment From: Steve Bruce

3/04/26 @ 12:51 PM Form Letter 1

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Comment From: Jay Brown

3/04/26 @ 12:47 PM Form Letter 1

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Comment From: Denise Broadwell

3/04/26 @ 12:35 PM Form Letter 1

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Comment From: Joana Bravo

3/04/26 @ 11:03 AM Form Letter 1

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Comment From: Nicolas Bossut

3/04/26 @ 11:02 AM Form Letter 1

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Comment From: Kyle Blount

3/04/26 @ 11:01 AM Form Letter 1

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Comment From: Martin Blais

3/04/26 @ 11:00 AM Form Letter 1

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Comment From: Ron Bischof

3/04/26 @ 10:59 AM Form Letter 1

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Comment From: Douglas Biggs

3/04/26 @ 10:58 AM Form Letter 1

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Comment From: David Berent

3/04/26 @ 10:57 AM Form Letter 1

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Comment From: William Bendush

3/04/26 @ 10:56 AM Form Letter 1

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Comment From: Stuart Becker

3/04/26 @ 10:55 AM Form Letter 1

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Comment From: Edward Beaver

3/04/26 @ 10:54 AM Form Letter 1

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Comment From: James Battocchio

3/04/26 @ 10:53 AM Form Letter 1

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Comment From: Alexander Barnachia

3/04/26 @ 8:33 AM Form Letter 1

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Comment From: Danny Barbour

3/04/26 @ 8:31 AM Form Letter 1

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Comment From: James Ayers

3/04/26 @ 8:30 AM Form Letter 1

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Comment From: Cynthia Ayala

3/04/26 @ 8:29 AM Form Letter 1

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Comment From: Steve Avalos

3/04/26 @ 8:28 AM Form Letter 1

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Comment From: Dennis Appelbaum

3/04/26 @ 8:26 AM Form Letter 1

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Comment From: Richard Antonucci

3/04/26 @ 7:43 AM Form Letter 1

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Comment From: Christopher Angelo

3/04/26 @ 7:42 AM Form Letter 1

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Comment From: Reza Amirani

3/04/26 @ 7:41 AM Form Letter 1

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Comment From: Roberto Alvarez

3/04/26 @ 7:32 AM Form Letter 1

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Comment From: Gabriel Aguilar

3/04/26 @ 7:24 AM Form Letter 1

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Comment From: Debbie Acosta

3/04/26 @ 7:20 AM Form Letter 1

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Comment From: Nick Krebs

3/04/26 @ 6:26 AM

The cost of gasoline in California is insane and out of control. Too many regulations are forcing refineries to close, pushing up the cost of gas and forcing us to secure gas from places halfway across the world, vastly increasing the amount of emiss...↓

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Comment From: Valerie Chan

3/04/26 @ 4:25 AM

Some of the proposed changes revise the 'ARB' acronym to 'CARB'; however, there are numerous places where 'ARB' remains unchanged. Please be consistent with the acronym used in the final regulation.

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Comment From: Valerie Chan

3/04/26 @ 4:17 AM

Please consider adding in written allowances for virtual/remote site visits in § 95977.1(b)(3)(D). For example, CARB can specify that virtual site visits are permitted in cases where the Verification Body / Offset Project-Specific Verifier has comple...↓

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Comment From: A Sahara

3/03/26 @ 3:50 PM

Regarding the initial crediting period and baseline modelling, there is a large incentive for project developers to develop aggressive baseline models to maximize the delta between initial carbon stocks and baseline carbon stocks, thereby maximizing ...↓near-term profits. Baseline models are complicated and underpinned by many assumptions regarding timber markets, growth in carbon stocks, and regulatory constraints. Forest dynamics are complex, and growth is difficult to model "accurately", even using local site and ecological data. Changes in environmental conditions over 100 years are impossible to know. Because of the inherent complexity in baseline modelling over long periods, it is difficult for verification bodies to be able to present strong and compelling evidence if they feel a baseline model is too aggressive, and it is an area that project developers can exploit to their advantage. Project developers often exit a project in 5-10 years, having developed a sophisticated project that is challenging for landowners to understand fully, and which may saddle the landowner with unrealistic growth expectations. This can lead to annual project reversals because actual project growth is not enough to overcome the project's baseline market responses to wood production changes and secondary effects reductions, and these reversals are then considered at least partially intentional because they result from poor modelling of the baseline, although they are often combined with extenuating circumstances like drought, pest infestations, or fire-fighting responses (e.g. emergency fuel break construction). Unfortunately for the landowner, the project developer has often exited from their contractual responsibilities when reversals appear and the landowner is left trying to understand a pay for project reversals due to lower than expected growth, often due to natural causes, but exacerbated by high baseline deductions. I have spoken to and worked with landowners whose project stocks are verifiably greater each year (i.e., project stocks increase annually), but still face negative QRy when all accounting is completed.
One avenue to minimize aggressive baseline modelling would be to spread the initial avoided emissions carbon credits over a longer period of time, like 10 to 20 years. This would also provide the project a buffer if project stocks do not grow at the rate initially modelled.

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Comment From: PBF Energy Inc. (PBF) (Rick Shih)

3/02/26 @ 4:50 PM

Please see attached file. Thank you.

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Comment From: Alex Chen

3/02/26 @ 4:08 PM

To Whom It May Concern,

Dear California Air Resources Board,

I am writing to express my support for strong and effective amendments to the California Cap on Greenhouse Gas Emissions and Market-Based Compliance Mechanisms Regulation. It is crucial t...↓

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Comment From: Alex Chen

3/02/26 @ 3:59 PM

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Comment From: A Sahara

3/02/26 @ 3:50 PM

Accounting for standing dead can be done in many ways in practice and is a common cause of issues during verification. It would be helpful for project development, monitoring, and verification if there was a single set of methods that all projects mu...↓

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Comment From: Justin Haubrich

3/02/26 @ 3:49 PM

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Comment From: Justin Haubrich

3/02/26 @ 2:58 PM

Please increase the caps.

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Comment From: California Fuels and Convenien... (Alessandra Magnasco)

3/02/26 @ 10:36 AM

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Comment From: Kevin Davis

2/27/26 @ 4:14 PM

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

2/09/26 @ 4:46 PM

February 2, 2026

Lauren Sanchez, Chair
California Air Resources Board
1001 I Street
Sacramento, CA 95814

RE: Concerns Regarding CARB's Draft Cap-and-Invest Proposal

Dear Chair Sanchez:
On behalf of the State Building and Construction Trades Counci...↓

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

2/08/26 @ 12:49 PM

Please find herewith our comment letter recommending that CARB establish a price floor and price inflator consistent with regulatory and statutory policy objectives.

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Comment From: Vincent Caboara

2/01/26 @ 4:02 PM

ADDENDUM: Formal Legal Entity Clarification for ACS

Please note that previous submissions under the name 'ACS' refer to the legal entity Arboreum Commercial Solutions, LLC. All technical feasibility data remains as filed on 12/17/25.

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Comment From: Vincent Caboara

2/01/26 @ 2:56 PM

Market-based compliance mechanisms should prioritize direct industrial displacement over external carbon offsets. Arboreum Commercial Solutions (ACS) has developed a carbon-negative industrial feedstock process using agri-waste (filed 12/17/25). This...↓

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Comment From: Trinity Public Utilities Distr... (Paul Hauser)

1/23/26 @ 12:49 PM

Trinity Public Utilities District is a non-profit publicly owned electric utility that meets the definition of an electric utility in California. Trinity Public Utilities District believes that we should receive allowances as part of this program.

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