The tide against a carbon cap-and-trade market appears to be rising. Following on the heels of an environmental justice coalition\u2019s opposition to a greenhouse gas commodity system, California legislators blasted state regulatory agencies for focusing on developing a carbon trading market for the power industry in place of proven greenhouse gas emission reduction measures. \u201cWe have not heard anything about greenhouse gas reduction numbers,\u201d Senator Christine Kehoe (D-San Diego), chair of the Senate Energy, Utilities, & Communications Committee, told California Air Resources Board and Public Utilities Commission officials at a joint hearing of the Assembly Resources and Senate Energy panels March 3. Kehoe noted during the oversight hearing that the state climate protection law, AB 32, seeks real global warming gas reductions, not merely \u201cdreaming up\u201d programs. \u201cThere are no checks and balances for cap-and-trade,\u201d added Assemblymember Lori Saldana (D-San Diego). However, Julie Fitch, CPUC director of strategic planning, defended her agency\u2019s and the California Energy Commission\u2019s joint recommendations to the California Air Resources Board. They call for the immediate development of a carbon cap-and-trade market for the electricity sector and address the underlying issue of who should be obligated to meet mandated emission reductions. The recommendations outlined in a joint document call for holding generating units that send power into the grid responsible for meeting AB 32 emission curbs, called a \u201cfirst deliverer,\u201d (previously dubbed \u201cfirst seller\u201d) instead of a \u201cload based\u201d approach, under which utilities are regulated. They also call for a large portion of the power industry greenhouse gas emission curbs to come through stringent energy efficiency and renewable requirements. The two commissions, which plan to vote on the proposed recommendations next week, advise the Air Board to impose renewable energy and efficiency standards on public power agencies, community choice aggregators, and other non-utility providers on par with those placed on investor-owned utilities. The Air Board is ultimately responsible for AB 32 implementation. Assemblymember Loni Hancock (D-Berkeley), chair of the Assembly Natural Resources Committee, asked for specifics on the claim that a cap-and-trade program would offer lower cost emission reductions. \u201cLower than what? And a cost to whom?\u201d she asked. Fitch said a cost analysis of emission reduction levels from a trading market will be included in a second round of recommendations by the CPUC, which are set to be released in August. Meanwhile, the Air Board staff said last week that it wants to take the CPUC-CEC ruling and \u201crun with it.\u201d Air Board chair Mary Nichols confirmed that, but added that a lot of details need to be first hashed out. She told lawmakers that her agency was exploring a variety of regulatory and market mechanisms, including a carbon tax. She said the agency is in compliance with the law, adding, \u201cWe are not under any delusion that we have solved the problem and are mindful that transformative steps need to be taken.\u201d By 2020, 174 million metric tons of carbon emissions per year are expected to be removed from California\u2019s air, with 66 million tons of reductions estimated to come from early voluntary actions, such as energy efficiency measures implemented before the law goes into effect. Environmental justice leaders also slammed the Air Board\u2019s AB 32 regulatory process. \u201cWe have gotten the cold shoulder from [the Air Board],\u201d said Jane Williams, chair of the board\u2019s Environmental Justice Advisory Committee, which was established under AB 32. She warned that \u201clarge utilities\u201d will reap the benefits of proposed emission reduction strategies, adding that higher utility bills \u201cdo little to protect poor communities from pollution.\u201d Bill Magavern, legislative director of Sierra Club California, asked lawmakers to ensure that air quality impacts and environmental justice concerns are also weighed before market mechanisms are considered. He urged legislators to require more transparency and accountability from the CPUC and other agencies involved in AB 32 implementation. He further called for the Air Board\u2019s AB 32 work to be funded by a fee on polluters.