First Name | James |
---|---|
Last Name | Wintergreen |
Email Address | jtw@firstenvironment.com |
Affiliation | First Environment, Inc. |
Subject | Comments regarding proposed revisions to the Mandatory Reporting Regulation |
Comment | First Environment offers the following comments regarding proposed revisions to the Mandatory Reporting Regulation. Consistent with our previous comments on this issue, First Environment does not support revision of the verification deadline from September 1 to August 1 without further revisions to the regulation to facilitate meeting this earlier deadline. Changing the deadline without making appropriate changes to the MRR to facilitate meeting the deadline will potentially result in a less impartial and/or rigorous verification process, less accurate GHG reports submitted to ARB, and a higher risk of missing the verification deadline for reporters which could result in enforcement action. If ARB changes the verification deadline from September 1 to August 1, First Environment proposes the following additional revisions to the regulation to facilitate successful verifications by the earlier date: 1. Relative to 95105, establish requirements for uploading specified supporting documentation to Cal eGGRT at the time the GHG report is submitted. We propose, at a minimum, that this documentation should include but not be limited to: a. Statement on operational control and related entities b. Electricity purchases/acquisition records c. Natural gas purchases/acquisition records d. Evidence of unit nameplate capacities e. Air district permits f. Internal meter calibration records g. Gross and net generation data h. Thermal energy generation data i. Product data evidence j. Records associated with any issue ARB defines as a high risk issue (e.g. contracts for biomass derived fuel) k. Specified source contracts for EPEs l. Specified source generation meter data for EPEs The verification body should be provided access to these uploaded documents through Cal eGGRT when the reporter selects the verification body in Cal eGGRT to provide verification services. 2. Relative to 95105(c) and 95105(d), establish requirements for uploading these documents to Cal eGGRT, which will encourage reporters to prepare for and begin verification activities earlier. We propose establishing a February 30 deadline for uploading these documents to Cal eGGRT. 3. Relative to 95131(a), establish a regulatory deadline for reporters for submission of the NOVS, which will encourage reporters to prepare for and begin verification activities earlier. We propose a May 30 deadline for submission of NOVS. 4. Relative to 95131(b)(3), establish a regulatory deadline for reporters for completion of verification site visits, which will encourage reporters to prepare for and begin verification activities earlier. We propose a June 30 deadline for completion of verification site visits. 5. Relative to 95131(c)(4), recognizing the proposed shortened verification period, reduce the notification and report correction period to five days. 6. Relative to 95133(e), establish a regulatory deadline for reporters for submission of the COI, which will encourage reporters to prepare for and begin verification activities earlier. We propose a May 1 deadline for submission of COI. Without these revisions to the MRR, First Environment requests that the verification deadline remain September 1. |
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Date and Time Comment Was Submitted | 2016-09-19 15:23:01 |
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