Submitted Comment Name Paul Kuzmenko Affiliation Liberty Packing Company, LLC Subject New Product Allocation Leakage Risk Message David and CARB staff, Thank you for the presentation. I agree that CARB should incorporate a mechanism to address a temporary period of leakage risk for new products. Liberty Packing Company is and has been directly affected by the lack of such a mechanism for the past number of years and will experience leakage risk on any new products that are not directly stipulated on Table 9-1. CARB should also provide allocation for prior years, corresponding to the start of production. This would be a welcome and prudent mechanism to minimize the leakage risk associated with new products that could take years to be added via a regulatory amendment. Thank you, Paul Kuzmenko File Upload (i.e., Attachments): N/A
Submission information