Comment Log Display

Excerpted from page 2 of attached letter:

"The notice of public hearing for both the MRR and Cap & Trade
proposed orders state that comments are due on October 23rd at noon
(Pacific) and that the public hearing is scheduled for October 24th
at 9 am.  As a procedural issue, Valero does not feel that industry
has sufficient time to comment on the proposed amendments in such a
way that CARB can fully address the comments and incorporate
appropriate changes to its regulatory language before the public
hearing with the CARB Board.  Further, the notice states “ARB
requests that written and email statements on this item be filed at
least 10 days prior to the hearing so that ARB staff and Board
members have additional time to consider each comment.”  While this
language is a request and not a requirement, the fact that the
Board hearing is scheduled to occur the morning after the deadline
for comments makes October 13th (Sunday) the de facto deadline for
submitting comments.  This, in effect, shortens the comment period
to 35 days and also short circuits discussions within trade
association and between trade associations and CARB, especially
pertaining to entirely new sections of the regulation (i.e.,
pertaining to reporting of Toxic Air Pollutants and Criteria
Pollutants under provisions of the Adaptive Management Plan). 
Valero suggests that CARB incorporate all appropriate comments into
the regulatory language for the Board hearing, as long as the
comments are submitted by the 23rd."