Comment Log Display

RE: PROPOSED AMENDMENTS TO THE REGULATION FOR THE MANDATORY
REPORTING OF GREENHOUSE GAS EMISSIONS (Second 15-day
Modifications)

Land O’Lakes, Inc (“Land O’Lakes”), on behalf of its dairy
production facility in Tulare, California, appreciates the
opportunity to provide comments to the California Air Resources
Board (“ARB”) in regards to the proposed second 15-day
modifications to proposed amendments to the Regulation for the
Mandatory Reporting of Greenhouse Gas Emissions (“Proposed
Modification”), which is posted on April 13, 2017 on ARB’s website.
 
In general, Land O’Lakes would like to express genuine gratitude
and appreciation to ARB staff for taking the comment of industry
into consideration during this rule-making process.  Although Land
O’Lakes agrees with most of proposed modifications related to Dairy
Product industry, we have a serious concern regarding the proposed
changes to move the deadline to complete verification of the annual
greenhouse (GHG) emission data reports earlier by approximately 22
calendar days from September 1 to August 10 each year.  
Land O’Lakes is opposed to the proposed modification to the
verification deadline because it will result in less amount of time
available for reporting and verification entities to work together
to complete the verification process.  We sense that ARB is likely
not taking into consideration other day-to-day compliance and other
regulatory work activities that the reporting industry staff and
verifiers perform while handling the verification project each
year.  The proposed earlier deadline will cause additional pressure
and burden to both parties and may lead to a compromise in the data
and verification work quality. As such, Land O’Lakes respectfully
request that ARB leave the September 1 verification date, as stated
in the current versions of the regulation.