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Comment 4 for Cap & Trade Public Meeting (cost-containment-ws) - 1st Workshop.


First Name: Bill
Last Name: Buchan
Email Address: buchan@mktpotential.com
Affiliation: Graphic Packaging International, Inc.

Subject: No Hard Floor for Auction Price Allowances
Comment:
GPI asks that ARB consider not adopting a hard floor for the
auction price of allowances.  This only serves to lock in the cost
of compliance for cap and trade for industry.  With the declining
cap, we suspect that the supply of allowances will be constrained,
so the market will appropriately keep prices elevated.   This in
turn will cause facilities to mitigate GHG as part or all of their
compliance under the cap.   So if supply is restricted through the
declining cap, there should be no need for a hard floor on the
auction price of allowances.

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Date and Time Comment Was Submitted: 2010-07-12 10:30:16



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