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Comment 65 for Cap & Trade PDR (dec-14-pdr-ws) - 1st Workshop.


First Name: Bill
Last Name: Buchan
Email Address: buchan@mktpotential.com
Affiliation: Graphic Packaging International

Subject: Regulation that Avoids Shutdowns or Reduced Output for GHG Reductions
Comment:
As the policy for the California Cap and Trade Program takes shape,
we urge ARB to develop and implement policy that will guide
industry to reduce GHG emissions through energy efficiency or
replacement with renewable fuels.   We are very concerned that the
policies under consideration may instead lead to higher costs for
businesses to a point where reductions are achieved through reduced
output of plant shutdowns, which leads to higher unemployment and
scarcity with higher costs for products targeted under the AB32
program (e.g. electricity).  We urge ARB to develop and review key
choices, such as free allocation or auction, in light of impacts of
industry during these recessionary times. 

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Date and Time Comment Was Submitted: 2010-01-11 16:03:36



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