First Name | Robert |
---|---|
Last Name | Ehlers |
Email Address | robert.ehlers@valero.com |
Affiliation | Valero |
Subject | Comment Period for Proposed Order for C&T Regulatory Amendments |
Comment | Excerpted from page 2 of attached letter: "The notice of public hearing for both the MRR and Cap & Trade proposed orders state that comments are due on October 23rd at noon (Pacific) and that the public hearing is scheduled for October 24th at 9 am. As a procedural issue, Valero does not feel that industry has sufficient time to comment on the proposed amendments in such a way that CARB can fully address the comments and incorporate appropriate changes to its regulatory language before the public hearing with the CARB Board. Further, the notice states “ARB requests that written and email statements on this item be filed at least 10 days prior to the hearing so that ARB staff and Board members have additional time to consider each comment.” While this language is a request and not a requirement, the fact that the Board hearing is scheduled to occur the morning after the deadline for comments makes October 13th (Sunday) the de facto deadline for submitting comments. This, in effect, shortens the comment period to 35 days and also short circuits discussions within trade association and between trade associations and CARB, especially pertaining to entirely new sections of the regulation (i.e., pertaining to reporting of Toxic Air Pollutants and Criteria Pollutants under provisions of the Adaptive Management Plan). Valero suggests that CARB incorporate all appropriate comments into the regulatory language for the Board hearing, as long as the comments are submitted by the 23rd." |
Attachment | www.arb.ca.gov/lists/com-attach/37-capandtrade13-AHZTNFQ5VGIAdAFu.pdf |
Original File Name | Valero MRR cmt ltr 10-17-13.pdf |
Date and Time Comment Was Submitted | 2013-10-17 14:22:49 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.