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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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