Comment Log Display

Tesoro disagrees with CARB’s proposed revision to the limited
exemption calculation in 95920(d)(2)(F).  The proposal will
substantially reduce our ability to manage the allowances needed
for compliance and current compliance flexibility found in the
regulation.  We specifically oppose the reduction in the limited
exemption by the amount of allowances that are required to be
surrendered when an annual compliance obligation is due.  We
understand that CARB has proposed this in order to provide some
‘equivalency’ to linked programs in Canada, but the Canadian
provinces do not have an annual surrender obligation so there is no
need for CARB to reduce our compliance flexibility based on the
approach in Canada.   That is to say that the Canada requirements
for surrender of obligations are already different than those in
California; therefore, there is no need for equivalency in the
amount of the limited exemption. This recent proposed change, when
added to existing restrictive holding limits, just makes compliance
more difficult for entities with large compliance obligations and
adds no program environmental benefit.