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Comment 60 for Proposed Amendments to the Cap-and-Trade Program (cap-trade-draft-ws) - 1st Workshop.
First Name: Bill
Last Name: Buchan
Email Address: buchan@mktpotential.com
Affiliation: Cardinal Cogen, Inc.
Subject: Reduce Naming Of Personnel in Registration
Comment:
It is overly burdensome with no clear value to specify all management personnel during registration even if some personnel have no involvement in cap and trade. This requirement is particularly excessive for large global organizations where the list of management personnel is extensive. Directors, officers, and persons controlling the voting rights of a large global entities are unlikely to have direct knowledge of cap and trade issues for a California subsidiary. New VAE language requests identification of corporate associations making extensive personnel requests from covered entities unnecessary.
Attachment: www.arb.ca.gov/lists/com-attach/62-cap-trade-draft-ws-AGFXIwFiWFQFMVdn.docx
Original File Name: ARB 2013 cap and trade comment - reduce naming personnel.docx
Date and Time Comment Was Submitted: 2013-08-02 16:57:14
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