First Name | Karl |
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Last Name | Gawell |
Email Address | karl@geo-energy.org |
Affiliation | Geothermal Energy Assn |
Subject | New Requirements for GHG Verification |
Comment | The Proposed Rule of the California Air Resource Board (17 CCR 950101 et seq) would require some geothermal operators (those emitting > 25,000 MT CO2e) to annually provide third-party verified compliance data despite their being without a compliance obligation. Meeting these new requirements will add significant expenses to these operators, costing each reporting unit tens of thousands of dollars annually, without any corresponding benefits to the environment given that any reasonable alternative to geothermal power generation would significant increase the emissions produced. We would urge CARB to modify this proposal and either remove the requirement for independent third-party verification or return to a 3- year verification requirement for these geothermal operators. |
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Date and Time Comment Was Submitted | 2012-09-14 09:37:05 |
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