Draft is here . Just the major points. First off, the proposal is basically pretty good . We should keep in mind that what WCI is doing represents a big -- gigantic -- step in the right direction for the climate. So I'll raise a glass to everyone who's worked so hard on the WCI proposal so far. But there's room for improvement . Below, I highlight the core areas of the proposal. These are bedrock issues that make me concerned. Transportation is in. Sort of. It appears that transportation fuels – the region’s largest source of carbon pollution – will be delayed until 2015, the second “compliance period.” The document is not crystal clear, but in Section 6, “Setting the Regional Cap,” it says that the regional cap will be adjusted in 2015 to add both transportation and the natural gas that is used in homes and businesses. (See 6.3). It's critical that we included transportation fuels ASAP. Auctioning is in limbo. WCI appears to be punting on this hugely important question. In past communications they’ve said that states and provinces will be required to auction a minimum percentage of between 25 and 75 percent of their allowances. In today’s draft (see 8.7) they say this: The issue of establishing a minimum percentage of allowances subject to auction by each Partner is still under discussion by the Partners. The Partners expect to make a recommendation on this issue by Fall, 2008. That's not wildly helpful. But in defense of WCI, t ...