| Comment | Attached and submitted via email to Mr. Richard Bode please find
United Airlines, Inc. (“United”) comments on the proposed
Amendments to the Regulation for the Mandatory Reporting of
Greenhouse Gas emissions (Mandatory Reporting Regulation, or
“MRR”), which are scheduled for adoption by ARB on October 24,
2013. As discussed in detail on the attachment, United’s principal
concern is the proposed MRR amendment in section 95104(e). This
proposed new section would require operators of affected facilities
to report whether an increase in toxic air contaminants (“TACs”) or
criteria pollutants may have occurred from its facility, and to
specify the reasons for such potential increases. Rather than
including this new section in the MRR, United respectfully suggests
that ARB should omit this proposed section and instead refer to the
emissions inventory information that the California Air Districts
and U.S. EPA maintain. United appreciates the opportunity to
comment on the proposed MRR amendments and urges consideration of
our comments.
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