Comment Log Display

To the Clerk of the Board:

Attached please find our comments to the proposed 15-Day Amendment
to the cap and trade regulation for post-2020 assistance factors
for our industry, the paperboard sector (NAICS Code 322130).  
ARB's approach and data for our sector do not adequately describe
the paperboard market, and therefore the proposed post-2020
assistance factors are inappropriate.  We provide recommendations
for addressing shortfalls in ARB's approach and data so that a more
accurate characterization of our sector with fair assistance
factors can be developed.  Under separate cover we are also
providing more detailed confidential business information to
support the attached recommendations.  Please give these
recommendations your strongest consideration in finalizing these
cap and trade amendments.


Bill Buchan, P.E.
On Behalf of Graphic Packaging International, Inc.