Van Ness Feldman is working with electric power entities in Arizona and the State of Washington that have become subject to California’s cap-and-trade program because of their imports of power into the state. On behalf of these entities, the firm has analyzed emissions reporting obligations and resulting allowance surrender obligations.  For one of the entities, the firm has advocated successfully before the California Air Resources Board for a modification to the allowance allocation for the entity’s in-state load, and providing advice on monitoring and reporting of the entity’s annual greenhouse gas emissions.