First Name | William |
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Last Name | Heatley |
Email Address | bill.heatley@graphicpkg.com |
Affiliation | Graphic Packaging International |
Subject | Appendix B: Development of Product Benchmarks for Allowance Allocation |
Comment | I understand and appreciate CARB needing to establish a greenhouse gas benchmark for each type of industry to determine allowances. However, when the type of industry is a population of one (such as our case) then that is not a benchmark. Statistically, a pool of twenty should be used to develop such a starting point. Since there is not twenty similar industries in the State of California, then the data source should be enlarged to incorporate such a pool. This will be accomplished soon with the manatory reporting on a national levels. Once this data is collected, then it should be used to develop a benchmark. Using a population of one to develop a standard is onerous and is very burdensome to the facility that must find means to reduce it's carbon footprint even though it may be the best in the nation or close down because the cost of credits outweigh the expected margin of the facility's profit. |
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Date and Time Comment Was Submitted | 2011-08-10 07:34:01 |
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