Comment Log Display

The draft requirements for corporate associations, direct
associations, and indirect associations is overly burdensome to
large, global entities and provides no real value to ARB.  Large,
global entities can have thousands of business units and
subsidiaries across the globe, many of which will have no business
in California or with the state’s cap and trade system.   Providing
this information is difficult to amass for such organizations and
provides no beneficial, actionable data to ARB.   Direct
associations ought to be limited to other covered entities in
California.  Indirect associations ought to be limited to entities
with operations in California or can participate in financial
investment transactions in California’s cap and trade system.  New
VAE language requests identification of corporate associations
making extensive listing of corporate, direct or indirect
associations from covered entities unnecessary.