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To whom it may concern, 

I am a GHG verifier with CARB.  If the verification submittal data
were changed from September 1 to August 1 this year, I would have
had at least 5 reporters with an adverse or qualified verification
statement.  Often times it take a reporter, even a seasoned report,
time to accurately report its GHG emissions or product data.  The
reason provided by CARB for this change is flawed at best.  There
seems to be no analysis provided for the impacts on the reporter
(who ultimately support the MRR program) and the VB who assist CARB
in the efforts to reduce GHG emissions throughout CA.  Please
provide a discussion of the impacts to the reporters and VB. 
Implementation of this change in Regulation without this analysis
could be a violation of CEQA.  To change the verification submittal
date based solely on CARB's inability to do its job is
unreasonable.  Verifier's and reporters have put in long hours to
conform to the requirement of the MMR and I would expect CARB to
understand and respect their commitment.