Our Work
Analytical Response to CARB’s ISOR Proposal for California’s Cap-and-Invest Program
March 2026
This brief evaluates alternative cap trajectories under CARB’s proposed updates to California’s Cap-and-Trade Program. Using Greenline Insights’ TRACE model, we compare CARB’s proposed cap with two higher-ambition pathways designed to illustrate how much additional climate ambition the program can achieve while maintaining affordability safeguards. The analysis finds that stronger cap trajectories improve long-term market balance and reduce the risk of persistent allowance surpluses and undersubscription while maintaining affordability. Across all scenarios evaluated, household impacts remain modest and progressive, with low- and moderate-income households continuing to receive net financial benefits on average through 2045.