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Comment 3 for Cap & Trade Public Meeting (cost-containment-ws) - 1st Workshop.
First Name: Bill
Last Name: Buchan
Email Address: buchan@mktpotential.com
Affiliation: Graphic Packaging International, Inc.
Subject: Removing Limit for Offsets
Comment:
Nicholas pointed out that a well-functioning cap-and-trade system would include no limits of the use of offsets. GPI supports this position. Unfortunately, ARB is considering rules that require that 51% reduction of GHG comes from onsite, limiting the use of offsets under the cap and trade program. For CHP, this is a rule that drives facilities to consider only big capital investments they can make in the turbine, for example. It locks out CHP from inexpensive investments they could make to reduce GHG in other sectors and jurisdictions through offset projects. For this reason, GPI recommends that CHP be exempted from the 51% rule.
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Date and Time Comment Was Submitted: 2010-07-12 10:30:16
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