Comment Log Display

June 13, 2013


Steven Cliff, Ph.D.
Chief - Climate Change Market Branch
California Air Resources Board
1001 I Street
Sacramento, CA 95812-2828

Re: American Beef Packers’ Comments on the Air Resources Board
Cap-and-Trade Public Meeting to Discuss Natural Gas Suppliers Under
the Cap-and-Trade Program

Dear Dr. Cliff: 

American Beef Packers appreciates the opportunity to submit these
comments on the Air Resources Board’s (ARB) June 3rd public meeting
to discuss how the natural gas supplier’s will be treated under the
cap-and-trade program. 

American Beef Packers is a significant user of natural gas.  In
this difficult economy, it is important that we manage our
operating costs.  Our natural gas bill is an important part of our
on-going operating costs.  If the full cost of carbon is passed
through to natural gas customers, our natural gas utility bill will
increase by 16%.  This would present a significant challenge to my
business and our competiveness with businesses outside of
California.

For nearly 25 years, California’s leadership in the area of air
quality has contributed to significant improvements in the
reduction of emissions.  Many years before AB32, the natural gas
sector stepped up to the challenge by advancing energy efficiency
programs and standards. As the utility representatives discussed at
the June 3rd workshop, natural gas utility customers in California
have already spent over $2 billion on energy efficiency programs
aimed at reducing natural gas use and associated greenhouse gas
(GHG) emissions.  As a result, the natural gas sector is already
below its 1990 GHG emissions levels years before the AB32 goal for
2020.

American Beef Packers is one of the many businesses in California
that has participated in one of SoCalGas’ energy efficiency
programs.  We have invested in a boiler replacement and new pipe
insulation. Through this partnership with SoCalGas, we have reduced
our natural gas use by a total of 55,327 therms.  In addition, our
business has added 210 jobs to the community of Chino.

While, we recognize the challenge California has to meet its 2020
goal.  We believe the contributions already made by the natural gas
sector should be acknowledged by ARB and factored into its plans
for providing allowances to the natural gas suppliers.

We support the joint utility proposal for ARB to provide the
utilities with 100% of their allowances in 2015 with a small
decline in free allowance through 2020.  This proposal will allow a
phasing in of the carbon price to natural gas customers, while
rewarding the sector for taking early actions to reduce emissions.

Thank you again for the opportunity to submit these comments.  We
look forward to continuing our work with ARB and other stakeholders
to ensure the successful implementation of Assembly Bill (AB) 32. 


Very truly yours,

Wade Carrigan, President
American Beef Packers, Inc.