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This comment relates to the proposal for verification related to
the recordkeeping and traceability requirements for waste and
residue feedstocks.  Under the proposal by CARB certification
systems that already provide such verification services under the
EU RED will not be recognized.  This has cost implications for
supply chains and for CARB, especially for international supply
chains, that use these systems and wish to supply the California
market. For supply chains that use EU approved certification
systems they will incur duplicate costs to provide the same
information to CARB as they provide to the EU.  For CARB it will
now need to incur substantial costs to duplicate the verification
infrastructure that the certification organizations offer globally.
One certification organization, ISCC, is active over 90 countries
and conducts training and oversight in the US, Canada, Europe,
China, South Asia and South America to ensure the low carbon fuel
requirements are verified for the EU.  CARB will need to provide an
equivalent communication, education, training and oversight service
to these supply chains inside and outside the US.  As a Canadian
working with the canola industry that supplies renewable fuel to
the California market I anticipate attending a CARB workshop in
Canada once the regulation takes effect.