Comment Log Display

July 9, 2013

Via web:  http://www.arb.ca.gov/cc/capandtrade/comments.htm

Ms. Rajinder Sahota
Cap and Trade Program
California Air Resources Board
1001 I Street, 
Sacramento, CA 95814

Subject:  Comments on the Proposed Amendment to the Cap and Trade
Regulation

Dear Ms. Sahota:

Thank you for an opportunity to comment on the proposed amendment
to the Cap and Trade regulation.   Tesoro has been working with ARB
staff regarding an appropriate cap adjustment factor and benchmark
for the Tesoro Wilmington Calciner (former BP Wilmington Calciner).
 Tesoro recommends the following changes to the proposed
amendment:

1.	The Cap Adjustment Factors for Allowance Allocation (Table 9-2)
should be revised to include calciners along with the other
identified sectors and activities that have process emissions
greater than 50%.  The recommended change would be to add another
row under those activities with process emissions greater than 50%
to include:

Sector								NAICS		Activity
All Other Petroleum and Coal Products Manufacturing		324199	     
Coke Calcining

Emissions from calcining operations are mainly process emissions.
At the Tesoro Wilmington Calciner, process emissions make up more
than 90% of the total emissions.  Tesoro suggests calcining be
treated consistent with the other activities with process emissions
greater than 50%.

2.	The Coke Calcining benchmark shown in Table 9-1 should be
revised to be consistent with the benchmark methodology outlined in
the ISOR, which is based on the higher of:

a.	90% of the average benchmark of California calciners, or
b.	Benchmark of the California best-in-class calciner

The benchmark in the existing Cap and Trade Regulation does not
accurately represent the California calciners and should be changed
to reflect California specific calciners.  Furthermore, the
benchmark for the calciner should not in any way be impacted by the
power produced by the bottom-cycling cogeneration plant.

Tesoro looks forward to working with ARB staff on the proposed rule
amendment.  If you have questions or need additional information,
please contact Ron Ricks at (310) 847-5647.

Sincerely


Daniel T. Riley