Comment Log Display

Tesoro appreciates the progress CARB has made addressing industry's
concerns regarding corporate association reporting.  We seek two
additional clarifications based on the language in the 15-day
package.

Tesoro understands that 95830 (c)(1)(H)(1) is created to allow
registered entity to use an alternate reporting method for direct
corporate association not registered in Cap-and-Trade and linked
ETS programs.  Alternative documents include SEC Form 10-K, FERC
application, NFA application, Form 40 or 40S filed with CFTC,
Part1A of Form ADV filed with SEC.  Other than this alternative all
information specified in 96833 (d)(1)-(2) must be reported.  Tesoro
understands the need to provide the information in 96833 (d)(1)-(2)
for all direct and indirect corporate association.  However, prior
CARB guidance indicated that such information was not necessary for
indirect corporate associations not registered in Cap and Trade or
linked jurisdiction.  This exception is not clear in the revised
language.  Tesoro proposes not to delete the “an unregistered
entity”  qualifier for indirect corporate associations in 95833
(d).

Secondly, please clarify which entities are referenced in the
language below (see question in parenthesis):

Last sentence of 95830 (f) -  If changes in information submitted
pursuant to section 95830(c)(1)(H) are related to entities (direct,
indirect, or both?) which are not registered in the Cap-and-Trade
Program or in a GHG ETS to which California has linked pursuant to
subarticle 12, and which are not involved in the line of direct or
indirect corporate associations between two registered entities,
the information must be updated within one year of the change at
least annually, instead of within 30 calendar days of the change.