Comment Log Display

On Behalf of Graphic Packaging International, we appreciate ARB's
common sense approach to providing free allocation to those
industry sectors who are trade exposed and risk of leakage.  While
we are pleased that ARB has incorporated leakage risk as an element
of the proposed regulation, ARB should consider making Ct in the
product-based benchmark equation equal to 1 for industrial sectors
in the “High” leakage risk category.  For these sectors which are
particularly sensitive to increased costs and competition from
outside the jurisdiction of the cap and trade market, it will not
be meaningful to offer 100% assistance or coverage with free
allocation and yet indicate that this only applies to a fraction of
the emissions that meet or exceed the industry’s benchmark.   These
facilities should be covered completely to ensure that they are not
put into a competitive disadvantage in the marketplace.