Comment Log Display

Valero appreciates the additional year ARB has provided for
monitoring and compliance purposes while the GHG inventory rule
development process continues.  We support ARB's ongoing efforts
to finalize this rule as expediently as possible in a manner
satisfactorily to all stakeholders.  However, the additional time
that has been necessary to reach this consensus has stretched rule
development well into 2008, leaving significantly less time for
assessing and implementing compliance strategies

We believe it is important for ARB to address the belated
publication of this rule and how that has created a need for
additional time for the design, purchasing, and installation of
some of the required monitoring equipment.  It is noted that the
rule allows for the manual collection of data to fill the interim,
and while we understand ARB's reluctance to further delay any of
the compliance deadlines, we recommend that the regulation include
a provision to allow alternative calculation protocols to be used
in the interim for those reporters who need more time to implement
projects.  It should be noted that most refineries are reporting
annually verified inventories to CCAR according to the CCAR
reporting and verification protocols.  While these are not
identical to the ARB regulations, the resultant inventories are
systematically developed using generally accepted, credible,
defensible, and verifiable techniques.  All or portions of the
CCAR inventories should be acceptable as temporary substitutes as
needed. 

Thank you for the opportunity to comment on this effort.  If there
are any questions or concerns, please contact me at number above.