November 1, 2021, is the compliance deadline for emitters covered under the California and Quebec Cap-and-Trade programs. One of the simplest compliance cost-saving strategies is for entities to take full advantage of their ability to substitute offsets for up to 8% of their total obligation. However, for the previous compliance period covering 2015-2017, California entities surrendered only 6.36% of the possible 8% offsets, and Quebec entities surrendered only 3.5% of the possible 8% offsets. Why did emitters leave so much potential savings on the table?

In late January 2020, the United States House Energy and Commerce Committee released a discussion document on the Climate Leadership and Environmental Action for our Nation’s (“CLEAN”) Future Act, which has the broad sweeping goal of reaching a “100% clean economy by 2050”. It is one of many attempts from the federal government to align goals for creating an economy that achieves carbon neutrality. So if we are seeing social, corporate and political trends towards a 100% clean economy, what is the role of legislation if action is already happening? Why are announcements like the CLEAN Future Act still meaningful and needed?