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Comment 68 for LCFS 2018 (lcfs18) - 45 Day.

First NameSTEFAN
Last NameUNNASCH
Email AddressUNNASCH@LIFECYCLEASSOCIATES.COM
AffiliationLife Cycle Associates, LLC
SubjectVerifier qualificaiton requirements
Comment
The Section 95502(c) of the draft regulation order indicates that
verifiers should have a strong understanding of the CI calculations
this is not necessarily true. Verifier should have an understanding
of following audit procedures and make sure that the inputs
correspond to the verification sheets. If ARB limits the knowledge
and scope of verifiers to verifying that receipts and evidence
exists the fuel producers will have a broader pool of potential
verifiers.

Attachment
Original File Name
Date and Time Comment Was Submitted 2018-04-23 14:53:44

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