CAP California Submits Comments on Proposed Updates to California’s Cap-and-Invest Program

Written By Audrey Payne

Clean and Prosperous California Executive Director Clayton Munnings recently submitted a public comment letter to the California Air Resources Board (CARB) on proposed updates to California’s cap-and-invest program. 

While we believe the proposal strikes a reasonable balance between climate ambition and affordability, we highlight opportunities to strengthen near-term emissions reductions and lower electric utility bills before 2030, including: 

  • Implementing the “offsets under the cap” policy in 2027 rather than 2028 

  • Distributing allowance reductions proportionally across between 2027 and 2030 rather than “backloading” these reductions

  • Growing the California Climate Credit pre-2030 by allocating more allowances to electric distribution utilities

Given the high social cost of carbon and allowance prices below the floor, further emissions reductions in the near-term are economically justified. And, given the price of electricity well above its social cost, efforts to reduce electricity bills are economically justified. Read the full letter here. 


Audrey Payne
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