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Comment 2 for May 4 Cap-and-Trade Electricity Workshop Comments (5-4-electricity-ws) - 1st Workshop.


First Name: Braydon
Last Name: Boulanger
Email Address: braydon_boulanger@transalta.com
Affiliation:

Subject: MAY 4 Comments
Comment:
TransAlta strongly encourages CARB to consider the following points
regarding Resource Shuffling:

1.Upfront determination of Resource Shuffling must occur.  We are
seeking an upfront process to individually determine what is, or is
not, considered Resource Shuffling.

2.If no changes are made to the current definition,there needs to
be a guidance document related to Resource Shuffling to expand on
the current definition.

3.CARB needs to be aware of the implications of how the MRR creates
a competitive advantage for those firms who can dispatch out of
their “system” versus those that do not. 
 

Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2012-05-10 14:03:15



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