| First Name: | Bill |
|---|---|
| Last Name: | Buchan |
| Email Address: | buchan@mktpotential.com |
| Affiliation | Graphic Packaging International, Inc. |
| Subject | Hard Ceiling for Auction Price Allowances |
| Comment |
GPI recommends that ARB consider the use of hard price ceiling. While some interesting options were noted for soft price ceilings, we are concerned that they will have limited effect. Can ARB carry a large enough reserve to ensure that auction prices do not escalate so high as to cause facilities to go out of business and how will this reserve be replenished? Over time the cost of offset projects is likely to escalate as the inexpensive projects have already been conducted. The use of future vintage allowances seems to be a temporary stop-gap measure, passing the problem into the next compliance period. A hard ceiling will give industry assurance that it understands the maximum cost of compliance and can make future plans accordingly. A sense of price certainty is critical for industry to manage its way through cap and trade and AB32. |
| Attachment |
Original File Name:
Date and Time Comment Was Submitted: 2010-07-12 10:30:16 |
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