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Dear ARB staff,

LRQA is concerned with the proposed change in the Regulation for
the Mandatory Reporting of Greenhouse Gas Emissions which would
move the verification deadline from September 1st to August 1st.
Much of the scheduling for our business outside of ARB work has
been structured around the ARB September 1st deadline. A change to
August 1st would have a significant impact on the number of
verification projects (both ARB and other voluntary and mandatory
programs) that LRQA would be able to perform in a given year with
adverse effects on our bottom line.

Your analysis results stating verification bodies can more
effectively use their time leading up to the verification deadline
is likely not taking into consideration work verification bodies
perform under programs not related to California initiatives. For
instance, LRQA’s team of verifiers are booked on verifications
under a number of voluntary programs from early spring through the
entire month of June. If ARB’s analysis has not taken into
consideration non-California related verification activities, the
analysis has not adequately address LRQA’s business situation and
that of many of the other ARB accredited verification bodies. With
the balance of schedules for various programs we work in, your
suggestion that a more effective use of time with a shift to
starting the verification cycle earlier would not alleviate the
adverse effects on our business.

Taking into consideration the adverse effect this will have on the
business of many of the ARB accredited verification bodies, if
there is an adequate internal need for ARB schedule adjustments, we
strongly encourage you to consider either a one or two week change
rather than an entire month.

Sincerely,
Derek Markolf
Americas Technical Manager Climate Change