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Testimony: Reforming California’s Cap and Invest program

California state capitol building in Sacramento. Photo by Allie Caulfield / Flickr

On February 23, 2026, the Joint Legislative Committee on Climate Change Policies held a hearing on the reauthorization of Cap and Invest, California’s climate program.

The following testimony was given to the committee by Allison Hilliard, Legislative Manager for The Climate Center:

I want to align my comments with NRDC’s and add that the proposed amendments represent small but necessary steps in the right direction. However, we face a rapidly worsening climate crisis approaching dangerous tipping points. Now is not the time to slow-walk our emission reduction efforts.

The proposed removal of 118.3 million allowances from the auction pool is the bare minimum required to meet California’s 2030 targets. As noted in the 2022 Scoping Plan, deeper reductions are needed to remain on track with our 2045 carbon-neutrality goals. We recommend removing at least 265 million allowances to generate a stronger pollution price signal and greater GGRF revenues.

We oppose the continued subsidies to fossil fuel industries through 100% Industrial Allocation Factors (IAFs) extended to 2035. These factors should be reassessed no later than 2031, based on analysis and evidence consistent with recent legislative direction. 

Furthermore, the proposed amendments to the Cap Adjustment Factor (CAF) for industry could potentially increase the share of free allowances to this sector, reducing GGRF proceeds and shortchanging urgently needed investments in community-based decarbonization and resilience.

Thank you for the opportunity to comment today, and we look forward to continuing to engage in this.