CARB Issues Court-Ordered Alternatives To California's Cap-And-Trade Program

On June 13, 2011, the California Air Resources Board (CARB) released a Supplement to its Functional Equivalent Document (FED) (the environmental review document for its cap-and-trade program). CARB was ordered by the San Francisco Superior Court to remedy deficiencies in the initial FED's analysis of alternatives to the cap-and-trade program proposed in the AB 32 Scoping Plan (for more information on this cap-and-trade program, please see our previous blog post).

This ruling was initially a tentative one, but was finalized on May 20, 2011. For more information on the Court's determination, please see our earlier blog post

The Supplement provides a more extensive analysis of the five alternatives to the Scoping Plan. These include: (1) a no project alternative, (2) an alternative based on cap-and-trade, (3) an alternative based on source-specific regulatory requirements, (4) an alternative based on a carbon fee or tax, and (5) an alternative program based on a