| Comment | At Graphic Packaging International, we applaud ARB for continuing
to address leakage issues for energy-intensive, trade-exposed
entities like our Santa Clara Mill. We encourage ARB to adopt a
goal to develop methodology that will prevent domestic and
international leakage where California facilities do not compete on
equal regulatory climate change footing. Leakage undermines our
ability to maintain jobs and sustainably produce local products for
Californians. While the proposed approach addresses leakage, we do
not yet believe this approach does enough to prevent leakage for
California covered entities.
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