A number of IETA members have participated in the quarterly RGGI CO
I make this certification in support of New Jersey’s motion to dismiss and brief filed inresponse to the complaint captioned Lagerkvist v. New Jersey Department of Environmental Protection, Docket No. ME-L-2185-10.5.
I understand that New Jersey Department of Environmental Protection has received arequest under its public records law seeking disclosure of information related to the firsteight RGGI CO
auctions, including, a) the names of all bidders, b) the price of each bid,and c) the quantity and type of CO
allowance sold to each successful bidder.6.
The purpose of this certification is to demonstrate that the information requested by the plaintiffs, including the names of bidders, the quantity and price of individual bids, andthe reward of allowances is proprietary information and should remain confidential.7.
Releasing such specific information about bidders could adversely affect participants,facilitate market manipulation, and make regional RGGI allowance auctions lesscompetitive.8.
Publicly releasing information related to bidding strategy and the quantity and price of allowances awarded could allow competitors to more accurately estimate a firm’s coststructure and use this information to their advantage.RGGI Market & Auction Characteristics9.
RGGI is unlike any environmental compliance market that is currently operating in theU.S. or elsewhere, in that the vast majority of allowances are obtained through theauction process instead of directly allocated to covered sources. Between 85 and 90