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Excerpts from general comments letter regarding:
1) Energy Efficiency Audits
Air Products agrees that continued focus on energy efficiency is
the GHG reduction strategy with the most positive economic impact.
 In requiring energy efficiency audits, CARB should develop
guidelines and allow those industries with the technical
capability to perform self-audits.  Regardless of who conducts
such audits, CARB must ensure the protection of Confidential
Business Information likely to be revealed through the audit
process.  CARB must also define the criteria for determining “cost
effectiveness” when considering rule provisions or permit
conditions to prescribe such measures, taking into account
differences between industries and competitive conditions of
individual facilities.

2) Sector-Based Measures for Refineries/Oil and Gas Production
Air Products supports efforts to provide regulatory incentives for
achieving continued process efficiency in refinery operations.  We
encourage CARB to consider the impact third-party support
facilities/processes contribute to overall refinery efficiency. 
Such efficiency improvements will also yield reductions in
criteria pollutants in particularly challenged air sheds. 

Original File Name:

Date and Time Comment Was Submitted: 2008-08-01 15:58:38