Comment Log Display

Tesoro is concerned with the overly broad requirement for
identifying corporate associations in 95833 and believes that these
associations should be limited to those located in CA or those that
participate in the CA GHG program - consistent with the WSPA
comments. 

Alternatively, if CARB is not willing to focus the language as
suggested above, the language should at least be made consistent
with 95912(d)(4)(E) regarding attestations and corporate
associations where the associations are limited to those who
“participate in a carbon, fuel, or electricity market”.
Changes should be made to sections 95833 (a)(1), (a)(2), (a)(3),
and (a)(4)

“An entity has a corporate association with another entity that
participates in a carbon, fuel, or electricity market, regardless
of whether the second entity is subject to the requirements of this
article,…”

The excerpt above with the proposed change is taken directly from
provision (a)(1), but the proposed change would be similar for the
other three provisions listed.