A Call for Changes
GANA Offers CARB Direction
by Bill Yanek
In June, the Glass Association of North America’s (GANA) Flat Glass Manufacturing
Division’s Climate Change Committee submitted comments to the California
Air Resources Board (CARB) in response to that organization’s May 17th
public meeting to discuss allowance allocation and the next steps for
a California cap-and-trade program. The comments call for several modifications
to the approach CARB is taking to cap-and-trade. Specifically, we asked
that CARB adopt:
1. Retention of free/subsidized allocations for flat glass producers below
2. Specific regulatory treatment and a working group meeting for the flat
3. Benchmarks based upon
a) the entire U.S. and not just California manufacturers;
b) differentiation between regenerative furnaces and oxy-fuel furnaces;
c) differentiation for different glass colors/types; and
d) consideration of the long life-cycle of a flat glass furnace.
4. Multi-year averaging for allocations instead of currently proposed
single year basis.
5. Retention of the assistance factor at 100 percent for the flat glass
GANA recognizes that CARB’s proposal to lessen the impact on manufacturing
by offering allocations to vulnerable industries is a way of reducing
the immediate impact of the cap-and-trade program in California. GANA
suggested, however, that any state or regional cap-and-trade program be
deferred in favor of a more unified national approach. This, we feel,
helps preserve the viability of manufacturing in California. Furthermore,
a patchwork of state and/or regional programs would create uncertainty
for businesses that operate nationwide and would expose the manufacturing
sector in the regulated states/regions to great business risk. That uncertainty
creates several possible adverse results that no state wants to face in
the middle of a difficult economy.
"… A patchwork
of state and/or regional programs would create uncertainty for businesses
that operate nationwide and would expose the manufacturing sector in the
states/regions to great business risk."
In California, the increased costs associated with a state cap-and-trade
program would be in addition to the already high cost of doing business
in California as a result of the existing stringent environmental regulatory
requirements. This situation has a high probability of causing carbon
leakage to other areas of the country or indeed to other countries, such
as Mexico, not covered by such programs.
In our letter to CARB, we suggested that CARB include all applicable regenerative
type float glass furnaces nationwide in the establishment of the emission
intensity benchmark, as opposed to restricting such scope again to only
California or even the Western Climate Initiative (WCI) region. The primary
reasons for this are: a) due to operational differences, container glass
furnaces and flat glass furnaces must be considered separately and b)
there are only three flat glass plants located in California. Restricting
the basis of the benchmark to California produces too small a sample for
establishing a representative intensity factor.
GANA also suggested to CARB that some consideration for furnace type be
included in the emission intensity benchmark. Specifically, separate benchmarks
should be developed for oxy-fuel type furnaces and regenerative type furnaces.
A full oxy-fuel fired glass furnace represents a fundamentally different
furnace design and would not be considered in the same category as any
operational or add-on controls that may be employed for control of emissions.
Including full oxy-fuel fired furnaces in establishing a benchmark based
on direct greenhouse gas emissions only would artificially skew the benchmark
against regenerative furnaces and force the industry toward a specific
As GANA continues to voice the needs of the industry to CARB and other
energy stakeholders, we need more industry voices to be part of the effort.
Learn how you can become involved by visiting our website at www.glasswebsite.com.
Bill Yanek is executive vice president of GANA. Mr. Yanek’s opinions
are solely his own and not necessarily those of this magazine.
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