Comment Log Display

The California Association of Sanitation Agencies (CASA)
appreciates the opportunity to comment on the Potential Amendments
to the Regulation for the Mandatory Reporting of Greenhouse Gas
Emissions. CASA is an association of California wastewater agencies
engaged in advancing the recycling of wastewater into usable water,
maximizing beneficial use of biosolids, generating renewable
energy, and producing other valuable resources. 

We have three comments for your consideration related to: 
- The potential consequence of changing the deadline for completing
third party verification services from September 1 to August 1,
2018 for the 2017 reporting year and each year following (as noted
in §95103(f) and (h)); 
- The alignment of the Reporting Regulation with Title 40 of the
Code of Federal Regulations Part 98 (40 CFR Part 98); and
- Annual verification requirements under §95130(a).

Please see the attached comment letter providing the full set of
comments for your review and consideration. Feel free to contact me
if you have any questions at (925) 705-6404 or
sdeslauriers@carollo.com. 

Sincerely,
Sarah A. Deslauriers
Climate Change Program Manager, CASA