| First Name | Brannen |
|---|---|
| Last Name | McElmurray |
| Email Address | brannen@nrgenergy.com |
| Affiliation | NRG Energy, Inc. |
| Subject | Error in Footnote 35 |
| Comment | Your proposed expansion of the protocols to Canada and Mexico is apparently limited in the context of an ODS offset protocol by the following footnote 35: "Staff does not intend to evaluate an ODS protocol for offset projects in Mexico because the substances covered under the protocol have not yet been completely phased out in developing countries." NRG believes that this limitation is in error because ODS substances covered by current ODS offset protocols were phased out by Mexico in 2005, under the Montreal Protocol and corresponding agreements. In addition, Mexico’s importation of CFCs ceased on January 1, 2010, inclusive of metered dose inhalers, because Mexico did not request an essential use exemption for any purpose. We have attached a letter more fully describing the error and request that the footnote be removed from the proposed regulations. Best, Brannen |
| Attachment | www.arb.ca.gov/lists/capandtrade10/978-brennen_mcelmurray.pdf |
| Original File Name | brennen mcelmurray.pdf |
| Date and Time Comment Was Submitted | 2010-12-14 13:39:38 |
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