Submitted Comment Name Jonah Kurman-Faber Affiliation Greenline Insights Subject Analytical Response to October 29th Workshop Message Dear CARB, Thank you for the opportunity to provide comments on the cap-and-invest program design options discussed at the October 29th, 2025 workshop. On behalf of Greenline Insights, I am submitting the attached analytical memo, which provides technical evaluation of several potential cap trajectories and emissions pathways using our California TRACE modeling framework. Our analysis is intended to support CARB's ongoing assessment of program stringency, long-term market balance, and distributional outcomes for California households. The memo includes detailed modeling of allowance supply under multiple cap trajectories, corresponding allowance price pathways, and net household impacts across income groups. We hope this information is useful as CARB considers potential refinements to the cap-and-invest program in the upcoming rulemaking process. Respectfully submitted, Jonah Kurman-Faber Founder & Principal Greenline Insights File Upload (i.e., Attachments): carb_workshop-response-analysis.pdf N/A
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