Comment Log Display

Graphic Packaging International supports the ARBs proposed change 
under 95856 (h)(1)(c) and (2)(c) to allow current year vintage
allowances up to the true-up amount for prior year compliance for
facilities with leakage risk as identified in Table 9-1 of section
95891(b).   We ask that ARB consider enhancing this provision by
removing the true-up amount limitation.   Allowing facilities to
use current year vintage for prior year compliance can provide a
strong cost containment benefit to EITE facilities.  Facilities
could now delay purchases of allowances if they thought future
prices of allowances would be cheaper.  As a facility with leakage
risk, we see our proposed change as a significant means for cost –
containment of cap and trade costs, a very important consideration
for all EITE facilities.