Ceres, in testimony at a California Air Resources Board (CARB) hearing and in written public comments, urged CARB to adopt California's updated cap-and-invest program without delay while preserving the program's integrity. It said delays would undermine market confidence, disrupt business planning and signal instability, and raised concerns about the proposed Manufacturing Decarbonization Incentive (MDI), which would allocate additional emissions allowances to support industrial decarbonization projects at manufacturing facilities. Ceres asked CARB to tie MDI monitoring and reporting explicitly to progress toward California's statutory climate milestones rather than only project-level outcomes. In comments submitted in May, it warned that creating millions of allowances outside and above the cap could weaken market integrity, depress allowance prices and reduce revenue for state programs.