As the California Air Resources Board (ARB) continues the development of regulations to implement AB 32, they have sought comments on ways to design their carbon offset program to not only meet their environmental objectives, but do so at the lowest possible cost.

Evolution Markets has strongly advocated for a robust program that creates carbon credits meeting the established criteria of being additional, quantifiable, permanent, verifiable, and enforceable. We also believe it is vital to provide the market clear -- and early -- signals on offset policy in order to stimulate immediate investment in carbon reductions.

In our comments to the ARB, we advocate for clear linkage to the existing offset protocols of the Climate Action Reserve (CAR), strong signals on the additionality benchmark and eligibility start date, and the abandonment of the "buyer liability" concept.

We encourage you to review our comments and share with us your thoughts on how ARB can craft a viable offsets program.