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Comment 30 for Workshop on Potential Amendments to MRR and Cap-and-Trade Regulation (mrr-cpp-ct-amend-ws) - 1st Workshop.
First Name: Lara
Last Name: Gertler
Email Address: lgertler@algcorp.com
Affiliation: Ashworth Leininger Group
Subject: Concern about Proposed Verification Deadline
Comment:
Thank you for the opportunity to submit comments on the recent workshop regarding proposed amendments to the MRR and cap-and-trade rules. In short, under the the proposed deadline, it would be very challenging to provide quality verification services. First, regarding the June 1 reporting deadline for EPEs, I do not feel that there is enough time between June 1 and the proposed August 1 verification deadline to adequately verify Electric Power Entities (EPEs) reports. Rajinder indicated that EPEs could always submit earlier and start the verification earlier. While that is true, presumably there is a reason why the EPE reports were due so late, e.g., data not being available earlier in the year. I recall that many do not have RECs retired until sometime in July. I imagine you are working on this aspect of things. I am simply concerned that while some will submit early, perhaps many EPEs cannot or will not, and that would not leave an adequate amount of time to do a good verification, and in fact may make it difficult for a reporter to find a verifier willing to take on the verification on that schedule. On a practical level, one thing that CARB should be aware of is that it is often very difficult to get quick turnaround from reporters on answering questions in June and July. Extremely difficult. Invariably, several key staff members are on vacation for a week or two at a time each. I realize the hope is that this would change if the regulatory deadline were moved, but the practical realities should be taken into account, to foresee and avoid the potential problems with a rule change. Following up on Rajinder’s discussion of the procedure on CARB’s end after verifications are submitted, CARB might consider running its QA/QC routines on the reports as soon as they are submitted, rather than waiting until after the verification. That would be helpful to all parties, and that way any “red flags” can be passed along to the verifiers at the beginning of the process to investigate, rather than waiting to catch problems afterward. I would recommend staggering the site visit requirement in the regulation so that not every facility is required to have a site visit in the first year of the compliance period. That adds yet another time pressure to the system, which would make it difficult to handle an August 1 deadline in those years. Perhaps you could allow the site visit to be delayed by a year or two if the reporter is using the same VB as previous years, and that VB has already performed a site visit. Or allow site visits before the report is submitted. You may want to add a provision to allow exemptions from the site visit requirement with approval from CARB. While the site visit is valuable, or even essential, for some facilities, for others it it pretty pointless. Most notably, for some electricity importers/exporters and transportation fuel suppliers, the critical verification activity is reviewing databases and contracts, and there is nothing that is done onsite that could not be done just as effectively via phone or computer conference (for example, using GoToMeeting to allow the reporter to demonstrate the data system). Often these entities are based out of state as well, which needlessly inflates the expense of the verification to the reporter. If you’d like to streamline the verification timeline, I would strongly suggest that CARB carefully consider and prioritize the reported data to focus and limit the scope of the verifications to certain types of data that are absolutely critical. The scope and work load has grown quite a bit over the course of the program, from basically just checking the accuracy and precision of data directly associated with the emissions at first, to now checking essentially every data point submitted. Is all of that really necessary? If so, that’s fine, but recognize that it takes time and effort. To achieve a quicker schedule, a more limited verification scope would seem to be a reasonable trade-off. Also, I would note that the single most frustrating element of the verification process in our experience, both for the verifiers and the reporters, is the requirement that every correctable error be corrected. Because of that, our Issues Logs are often littered with lots of very minor errors that have absolutely no consequences with respect to the report. And these both frustrate (and frankly, sometimes infuriate) the reporters and divert the focus from the important issues that need to be addressed. Follow-up on these super-minor issues eat up an disproportionate time of the verification. It kind of goes to the comment that one gentleman made in the meeting that 1% of the verification takes a large portion of the time. I understand that CARB desires error-free reports, but there should be a reasonable threshold for requiring action, below which correction is not required. Where should that threshold be set? I don’t know, but any threshold would be better than the absolute that is now in place. Again, I think prioritization is in order, if the schedule is to be compressed. Thanks as always for your hard work and consideration. I look forward to future workshops on the matter. Regards, Lara
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Date and Time Comment Was Submitted: 2016-03-11 16:53:35
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