Comment Log Display

As facility in a highly trade exposed industry (paperboard), we are
concerned that market prices for allowances at $25/ton and above
are going to have a severe impact on our business.  As we are trade
exposed, we cannot pass these costs onto our customers as we
compete with firms outside the jurisdiction of ARB.  To alleviate
this potentially severe impact on our manufacturing business and
the jobs we provide Californians, we suggest that ARB look
specifically at the pricing impacts on highly trade exposed
industries, potentially reducing or removing the cap adjustment
factor for highly trade exposed industries or waiving it when a
certain price trigger (e.g. $25/ton) is hit.  The cap adjustment
factor exceeds the growth expected in our industry, preventing us
from keeping pace from an earnings perspective.  It becomes a
severe penalty as the price of allowances reaches $25/ton. 
Controlling the costs of the cap adjustment factor for our highly
trade exposed industry is vitally important to allowing our
industry to sustain its manufacturing operations and keep
Californians employed.