Policy Overview

California is updating its Cap-and-Trade Regulation to reflect the increased ambition of the state’s 2022 Scoping Plan (see InfluenceMap’s policy tracker for more details), which raised the ambition of the state’s 2030 emissions reduction target from 40% to at least 48% below 1990 levels.

California’s Cap-and-Trade Program took effect in 2012 and was linked with Québec’s own carbon market in 2014. The program targets significant emitters of greenhouse gases (GHGs), which includes power plants, industrial facilities, and fuel distributors. To remain compliant under the policy, emitters may reduce their GHGs, purchase allowances, and/or rely on offsets to cover their emissions. With each allowance being equal to one metric ton of carbon dioxide equivalent, the cap-and-trade allowances are increasingly stringent over time, such that the cap decreases and fewer allowances are allocated each year. For the purpose of addressing cost and emissions leakage concerns, free allowances – allowances that are given out by the state and that certain entities do not need to purchase – are granted to select utilities and industrial facilities.

Although the California Air Resources Board (CARB) has yet to issue a formal rulemaking, its October 2024 notice proposes to raise the stringency of the program by lowering the amount of allowances and increasing the cost of compliance. Among other changes, the notice states that the scope of the expected amendments will include the removal of up to 265 million allowances in aggregate from the 2026-2045 annual budgets, updates to the free allowance allocations, and an increase in the price of the cost-containment provisions to better align with the federal government’s updated social cost of carbon. During the workshop presentations, CARB presented scenarios with emissions reduction targets of 48% and 55% by 2030, offering a range of ambition.

It is unclear if the program will link with other existing emissions trading schemes, however in March 2024, the governments of California, Washington, and Québec announced their official interest in creating a shared carbon market. In May 2025, Governor Newsom proposed a budget that would extend the Cap-and-Trade Program to 2045 and be rebranded as a “Cap-and-Invest” program.

Policy Status

Following the finalization of California’s 2022 climate plan, CARB held a series of workshops and meetings to receive input on potential amendments to the Cap-and-Trade program. Although CARB originally expected to propose a formal rulemaking by the end of 2024, its website states that it plans to move through a regulatory package sometime in 2025.

Policy Status

LIVE – Undergoing revisions, formal proposal expected in 2025.

Evidence Profile

Key

opposing not supporting mixed/unclear
supporting strongly supporting

Policy Engagement Overview

InfluenceMap’s assessment of corporate engagement across CARB’s workshops held between June 2022 and July 2024 suggests that the formal proposal may receive some pushback from utilities, energy sector companies, and their industry associations.

InfluenceMap notes the following engagement trends, across the comments submitted during CARB’s workshops:

  • The International Emissions Trading Association (IETA) advocated for lower emissions cap levels and urged CARB to model a scenario with a more ambitious emissions target of 55% by 2030. However, IETA exhibited a preference for the cap-and-trade program over other forms of climate policy, by stating that it was “much more effective at ensuring the achievement of ambitious climate targets than direct regulations or government subsidies.”

  • California utilities – namely Pacific Gas & Electric (PG&E), Edison International subsidiary Southern California Edison, and Sempra subsidiaries SoCalGas and SDG&E – appeared to advocate against any significant changes to the free allowances allocated to gas and electric utilities, while taking various positions on other suggested amendments. These utilities engaged individually and within coalitions, including the Joint Utilities Group (JUG) and the Gas Utility Group, which emphasized affordability concerns with any changes to utility allowance allocations. Sempra subsidiaries submitted comments that called for CARB to maintain allocated allowances for gas suppliers, with SoCalGas appearing to advocate for the cap-and-trade program to incentivize various fuels, including “synthetic natural gas,” as an alternative to ambitious near-term decarbonization. Southern California Edison also cautioned against changes to free allowances, although it also advocated for CARB to raise the “validation and verification” of eligible carbon offset projects.

  • The Western States Petroleum Association (WSPA) advocated for a weaker program update through several angles, including by calling for an allowance budget beyond 2030 that delays rapid emissions reductions in the near-term. The group also urged CARB to investigate the emissions associated with “policy-driven demand” and emphasized that the state’s zero-emission vehicle mandate and limits on in-state oil and gas development would result in greater emissions leakage than market-based approaches.

  • WSPA’s members, including Shell and Phillips 66, similarly advocated against significant changes in ambition to the cap-and-trade program, with Phillips 66 explicitly endorsing WSPA’s comments.

  • Several entities called for greater incentives for various fuels including fossil gas, hydrogen, and renewable natural gas. WSPA and Sempra subsidiaries took these positions, as did Marathon Petroleum, which advocated for CARB to exempt all forms of biomass regardless of source to be exempt from compliance obligations.

  • Morgan Stanley also appeared to advocate for a moderated approach, submitting October 2023 comments cautioning against “hastily implemented changes” and calling for CARB to delay changes until at least 2026.

Policy Status

LIVE – Undergoing revisions, formal proposal expected in 2025.

Evidence Profile

Key

opposing not supporting mixed/unclear
supporting strongly supporting

Entities Engaged on Policy

Influencemap Performance BandOrganizationPolicy PositionPolicy Engagement Intensity