Comment Log Display

Graphic Packaging International appreciates the theoretical
analyses that has been conducted for domestic and international
leakage.  It represents solid, critical thinking as to what should
or might happen in the marketplace.  What is unsettling about the
ARB approach is that these theoretical analyses are solely based on
business school theory and some data prior to 2013 before
California’s cap and trade program was implemented.  No effort has
been made to validate the theory with present day data to determine
what output has actually been lost from 2013-15 since cap and trade
begun.  Theory must be validated before putting it to use. 
Industry can provide insight into the actual impact the cap and
trade program has had on lost output, if not actual data in the
2013-15 period, and the current competitive pressures it faces from
international and domestic entities without a similar cap and trade
program.   We encourage ARB to validate these theoretical
approaches with actual, recent trade data wherever possible and
work with industry to gain insight as to the impact that the cap
and trade program has had and the real competitive pressures facing
California energy-intensive, trade-exposed entities.