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Analytical Response to CARB’s October 29th, 2025 Cap-and-Invest Workshop
November 2025
This brief provides a technical assessment of CARB’s proposed cap-and-invest adjustments presented on an October 29th, 2025 workshop. Using Greenline Insights’ TRACE model, we evaluate two interpretations of CARB’s planned removal of 118.3 million allowances from 2027-2030, along with a third higher-ambition pathway, each tested under two emissions scenarios. The results show that lower ambition leaves a large surplus of allowances and sustained price-floor outcomes, while moderate and higher ambition caps improve long-term market balance and stay within price-containment limits. Across all scenarios, household impacts remain modest and progressive, with low and moderate income households seeing net benefits on average through 2045.