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Comment 13 for Cap and Trade 2016 (capandtrade16) - 45 Day.

First NameBill
Last NameBuchan
Email Addressbuchan@mktpotential.com
AffiliationGRAPHIC PACKAGING INTERNATIONAL INC
SubjectLeakage Approach Needs to Prevent Leakage
Comment
At Graphic Packaging International, we applaud ARB for continuing
to address leakage issues for energy-intensive, trade-exposed
entities like our Santa Clara Mill.   We encourage ARB to adopt a
goal to develop methodology that will prevent domestic and
international leakage where California facilities do not compete on
equal regulatory climate change footing.   Leakage undermines our
ability to maintain jobs and sustainably produce local products for
Californians.  While the proposed approach addresses leakage, we do
not yet believe this approach does enough to prevent leakage for
California covered entities.

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Date and Time Comment Was Submitted 2016-09-16 13:14:23

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