First Name | Erin |
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Last Name | Quinn |
Email Address | equinn@analyticalcorp.com |
Affiliation | AES |
Subject | GHG Mandatory Reporting Regulation, change of verification deadline |
Comment | To whom it may concern, I am a GHG verifier with CARB. If the verification submittal data were changed from September 1 to August 1 this year, I would have had at least 5 reporters with an adverse or qualified verification statement. Often times it take a reporter, even a seasoned report, time to accurately report its GHG emissions or product data. The reason provided by CARB for this change is flawed at best. There seems to be no analysis provided for the impacts on the reporter (who ultimately support the MRR program) and the VB who assist CARB in the efforts to reduce GHG emissions throughout CA. Please provide a discussion of the impacts to the reporters and VB. Implementation of this change in Regulation without this analysis could be a violation of CEQA. To change the verification submittal date based solely on CARB's inability to do its job is unreasonable. Verifier's and reporters have put in long hours to conform to the requirement of the MMR and I would expect CARB to understand and respect their commitment. |
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Date and Time Comment Was Submitted | 2016-09-12 13:23:34 |
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