First Name | Bill |
---|---|
Last Name | Buchan |
Email Address | buchan@mktpotential.com |
Affiliation | |
Subject | Market Prices at $25/ton and Above |
Comment | As facility in a highly trade exposed industry (paperboard), we are concerned that market prices for allowances at $25/ton and above are going to have a severe impact on our business. As we are trade exposed, we cannot pass these costs onto our customers as we compete with firms outside the jurisdiction of ARB. To alleviate this potentially severe impact on our manufacturing business and the jobs we provide Californians, we suggest that ARB look specifically at the pricing impacts on highly trade exposed industries, potentially reducing or removing the cap adjustment factor for highly trade exposed industries or waiving it when a certain price trigger (e.g. $25/ton) is hit. The cap adjustment factor exceeds the growth expected in our industry, preventing us from keeping pace from an earnings perspective. It becomes a severe penalty as the price of allowances reaches $25/ton. Controlling the costs of the cap adjustment factor for our highly trade exposed industry is vitally important to allowing our industry to sustain its manufacturing operations and keep Californians employed. |
Attachment | |
Original File Name | |
Date and Time Comment Was Submitted | 2011-08-05 13:27:37 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.