Comment Log Display

June 17, 2013


Steven Cliff, Ph.D.
Chief - Climate Change Market Branch
California Air Resources Board
1001 I Street
Sacramento, CA 95812-2828

Re: Ashland Inc.’s Comments on the Air Resources Board
Cap-and-Trade Public Meeting to Discuss Natural Gas Suppliers Under
the Cap-and-Trade Program

Dear Dr. Cliff: 

Ashland Inc. appreciates the opportunity to submit these comments
on the Air Resources Board’s (ARB) June 3rd public meeting to
discuss how the natural gas supplier’s will be treated under the
cap-and-trade program. 

Ashland is a significant user of natural gas.  In this difficult
economy, it is important that we manage our operating costs.  Our
natural gas bill is an important part of our on-going operating
costs.  If the full cost of carbon is passed through to natural gas
customers, our natural gas utility bill will increase by up to 16%.
 This would present a significant challenge to my business and our
competiveness with businesses outside of California.

For nearly 25 years, California’s leadership in the area of air
quality has contributed to significant improvements in the
reduction of emissions.  Many years before AB32, the natural gas
sector stepped up to the challenge by advancing energy efficiency
programs and standards. As the utility representatives discussed at
the June 3rd workshop, natural gas utility customers in California
have already spent over $2 billion on energy efficiency programs
aimed at reducing natural gas use and associated greenhouse gas
(GHG) emissions.  As a result, the natural gas sector is already
below its 1990 GHG emissions levels years before the AB32 goal for
2020.

Ashland is one of the many businesses in California that has
participated in one of SoCalGas’ energy efficiency programs.  We
were invested in equipment modernization, including steam traps and
heat recovery systems.  Through this partnership with SoCalGas, we
have reduced our natural gas use by a total of 328,270 therms so
far.  

While, we recognize the challenge California has to meet its 2020
goal.  We believe the contributions already made by the natural gas
sector should be acknowledged by ARB and factored into its plans
for providing allowances to the natural gas suppliers.

We support the joint utility proposal for ARB to provide the
utilities with 100% of their allowances in 2015 with a small
decline in free allowance through 2020.  This proposal will allow a
phasing in of the carbon price to natural gas customers, while
rewarding the sector for taking early actions to reduce emissions.

Thank you again for the opportunity to submit these comments.  We
look forward to continuing our work with ARB and other stakeholders
to ensure the successful implementation of Assembly Bill (AB) 32. 


Very truly yours,


Aaron Jenkins, PE
Plant Engineer

Ashland Performance Materials
Division of Ashland, Inc
6608 E 26st Street
Los Angeles, CA 90040