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Comment 9 for Cap & Trade Public Meeting (may-17-allocation-ws) - 1st Workshop.
First Name: Bill
Last Name: Buchan
Email Address: buchan@mktpotential.com
Affiliation: Graphic Packaging Int., Inc.
Subject: Allocation Approach
Comment:
GPI is glad to see that ARB is thinking about GHG allocation based on output-based GHG efficiency. We also think that cost-effectiveness of technology required to meet efficiency targets should be considered. In this way, ARB can adjust the allocation standard downward over time only when it is cost-effective retrofits are justified. This is how retrofit regulations have been implemented in California, and we would hope that ARB does not deviate from this approach for AB32.
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Date and Time Comment Was Submitted: 2010-06-07 09:02:48
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