In a preliminary step toward implementation of a greenhouse gas cap-and-trade program under the Global Warming Solutions Act of 2006 (AB 32), the California Air Resources Board (“CARB”) on November 24, 2009 released a broad proposal identifying sources of emissions to be capped and the general timeline on which emission allowances must be obtained by capped industries. Under AB 32, California must reduce its greenhouse gas emissions to 1990 levels by the year 2020. As currently framed, the cap-and-trade program would account for just 20 percent of these total emission reductions.