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Air Products agrees market-based mechanisms will drive the most
economic efficient solutions to meeting the state’s reduction
goal.  We encourage CARB to consider a process for the allocation
of emission allowances that recognizes those industries that have
already invested in state-of-the-art efficient processes.   As
such, a Cap and Trade program can simultaneously advance the
objectives of economically efficient greenhouse gas (GHG)
reductions and energy/process efficiency.

Air Products also supports a broad flexibility in the use of
cross-border (WCI) allowances and offset purchases to further
minimize the overall economic impact of achieving the desired GHG
reductions.