First Name | Miles |
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Last Name | Heller |
Email Address | miles.t.heller@tsocorp.com |
Affiliation | Tesoro |
Subject | C&T 15-day package comment |
Comment | Tesoro is concerned with the overly broad requirement for identifying corporate associations in 95833 and believes that these associations should be limited to those located in CA or those that participate in the CA GHG program - consistent with the WSPA comments. Alternatively, if CARB is not willing to focus the language as suggested above, the language should at least be made consistent with 95912(d)(4)(E) regarding attestations and corporate associations where the associations are limited to those who “participate in a carbon, fuel, or electricity market”. Changes should be made to sections 95833 (a)(1), (a)(2), (a)(3), and (a)(4) “An entity has a corporate association with another entity that participates in a carbon, fuel, or electricity market, regardless of whether the second entity is subject to the requirements of this article,…” The excerpt above with the proposed change is taken directly from provision (a)(1), but the proposed change would be similar for the other three provisions listed. |
Attachment | |
Original File Name | |
Date and Time Comment Was Submitted | 2014-04-04 15:27:28 |
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