Comment Log Display

First Environment offers the following comments regarding proposed
revisions to 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.