| Comment | Your proposed expansion of the protocols to Canada and Mexico is
apparently limited in the context of an ODS offset protocol by the
following footnote 35:
"Staff does not intend to evaluate an ODS protocol for offset
projects in Mexico because the substances covered under the
protocol have not yet been completely phased out in developing
countries."
NRG believes that this limitation is in error because ODS
substances covered by current ODS offset protocols were phased out
by Mexico in 2005, under the Montreal Protocol and corresponding
agreements. In addition, Mexico’s importation of CFCs ceased on
January 1, 2010, inclusive of metered dose inhalers, because Mexico
did not request an essential use exemption for any purpose.
We have attached a letter more fully describing the error and
request that the footnote be removed from the proposed
regulations.
Best,
Brannen
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