Persisting delays in the California cap-and-trade program reform process have made it highly unlikely that new supply caps will be implemented by 2026. Considering the series of regulatory and legislative processes that need to be completed for the draft regulation to become law, the Initial Statement of Reasons (ISOR) must be published by the first week of July for a 2026 implementation to be potentially feasible. Even so, the California Air Resources Board (CARB) would still face many challenges both meeting submission deadlines and compensating for its distribution of allocated allowances in October this year.
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