Comment Log Display

Dear ARB,
 
We appreciate the opportunity to provide comments on the
“Amendments to Mandatory Reporting and Cap-and-Trade Regulations.”
We would like to bring to your attention of our serious concern
over ARB’s proposal to change the verification deadline from
September 1 to August 1. While we understand the need to have this
change of deadline to better support cap-and-trade regulation
allocation and compliance, it would critically shorten the time to
an already very tight verification season. Our verifiers have
conducted many verifications over the years, we strive to provide
the best and high quality service to our clients. However, losing a
month of time to complete such verifications would make it very
challenging to provide the full attention to each and every
verification we complete. Should you go forward with shortening an
already very tight verification season, we will still absolutely
provide the highest quality service possible but please keep in
mind this deadline change will significantly impact every
verification body and their clients work. 
 
In the webinar, it stated that reporters and verifiers can more
effectively use time leading up to the verification deadline,
however, in our experience reporters need all the time given to
meet the reporting deadline, particularly for a complex facility
such as an oil and gas producer. The verifier must wait to
officially begin work until the contract is signed, report is in
the system, the COI has been submitted and processed. Currently, we
do use the time leading up to the verification season as
effectively as possible but when you have no control over time of
another entity’s work or critical path, it is extremely difficult
to be at the end of the process that have to catch up with a season
cut short. 

We sincerely ask you to reconsider changing the verification
deadline from September 1 to August 1.

Thank you,
Erica Alvarado