Comment Log Display

Solar Turbines (Solar) is an 83-year California Company with its
corporate headquarters and two primary manufacturing facilities in
San Diego.  This includes 3,800 employees in California and more
than 7,000 worldwide.

Solar had been a member of the California Climate Action Registry
since 2006 and is a Climate Action Leader, and a new member of the
Climate Registry.  The San Diego Kearny Mesa facility, where all
new products are packaged and shipped, has reported and verified
GHG emissions under the ARB reporting regulation and is subject to
the Proposed Cap and Trade Regulation.  Emissions are generated by
turbine testing for research and development, and performance and
safety testing required by customers.

Since adoption of the Regulation on December 16, 2010, Solar has
presented detailed information to ARB staff about our business and
operations, and the impacts of proposed Benchmarks.  Staff have
been very responsive, and have proposed a revised Benchmark for our
industry sector that better reflects our manufacturing operations. 
Solar will still, however, be challenged to meet allowance
obligations.

On the subject of Emissions Leakage, Solar remains concerned about
the assistance factor category for our industrial sector.  In
particular, we recommend Staff further evaluate the mechanisms for
evaluating Trade Exposure for our industry sector.  It is our
understanding that Staff will be revisiting Leakage and we look
forward to working with them in 2012, or sooner if possible.

In summary, while Solar remains very concerned about the long-term
impacts of AB 32 on our ability to compete in a global market, and
our customers and suppliers, we support the revisions to the Cap
and Trade Regulation.  

Sincerely,


Craig Anderson
Director, Environmental Affairs
Solar Turbines