First Name | James |
---|---|
Last Name | Wintergreen |
Email Address | jtw@firstenvironment.com |
Affiliation | First Environment, Inc. |
Subject | Comments regarding proposed revisions to the Cap and Trade regulation |
Comment | First Environment offers the following comments regarding proposed revisions to the Cap and Trade regulation. Proposed revision to the regulation: 95977.1(b)(3)(R)8 – If ARB or the Offset Project Registry determines that the detailed verification report required pursuant to 95977.1(b)(3)(R)4.a. does not contain sufficient information to substantiate the attestations in the Offset Verification Statement, then the verification body must submit a revised verification report and a revised Offset Verification Statement to ARB or the Offset Project Registry within 15 calendar days. Comment: The language “does not contain sufficient information to substantiate the attestations in the Offset Verification Statement” is vague and does not provide an objective basis for the Offset Project Registry (or verification bodies) to determine whether the verification report meets the requirements of 95977.1(b)(3)(R)4a. To ensure consistency across Offset Project Registries and between verification bodies, the regulation should state the specific criteria that a verification report must meet or refer back to 95977.1(b)(3)(R)4a for the requirements that the report must address to be considered in conformance with the regulation. Proposed revision to the regulation: 95977.1(b)(3)(R) – Offset verification services are not complete until ARB offset credits are issued for the GHG emission reductions and GHG removal enhancements reported in an Offset Project Data. Comment: While verification bodies may anticipate questions and comments from ARB or the OPR after submittal of the verification report and statement, the regulation should not define the period between this submission and issuance of ARB offset credits to be part of “verification services.” Consistent with international best practices in financial auditing, third party audit services must have a defined scope including specific starting and ending dates during which the assessment of evidence was performed. To avoid unnecessary uncertainty regarding the scope of the verification process, verification services should be considered complete after the submission of the report and statement to the OPR. This proposed revision should be removed and the regulation can continue to rely on the existing text at 95977.1(b)(3)(S), which states that verification requirements are considered to be met when ARB Offsets are issued. |
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Date and Time Comment Was Submitted | 2016-09-19 15:17:40 |
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