First Name: | Bill |
---|---|
Last Name: | Buchan |
Email Address: | buchan@mktpotential.com |
Affiliation | Graphic Packaging International, Inc. |
Subject | Use of Current Year Allowance for Prior Year Compliance |
Comment |
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. |
Attachment |
www.arb.ca.gov/lists/com-attach/66-cap-trade-draft-ws-UjMHcwFiBwsCNgU1.docx Original File Name: ARB 2013 cap and trade comment - Current year allowance for prior year compliance.docx
Date and Time Comment Was Submitted: 2013-08-02 17:11:43 |
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