First Name | Craig |
---|---|
Last Name | Anderson |
Email Address | anderson_craig_d@solarturbines.com |
Affiliation | Solar Turbines |
Subject | Proposed Updated Regulation to Implement the Cap and Trade Program |
Comment | 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 |
Attachment | |
Original File Name | |
Date and Time Comment Was Submitted | 2011-08-10 11:24:48 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.