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Comment 11 for Workshop on Potential Amendments to MRR and Cap-and-Trade Regulation (mrr-cpp-ct-amend-ws) - 1st Workshop.
First Name: Kevin
Last Name: Townsend
Email Address: ktownsend@bluesource.com
Affiliation: Blue Source, LLC
Subject: Proposed Changes to the Cap and Trade Program
Comment:
Thank you for the opportunity to comment. Blue Source would like to express its support for the points raised in the letter submitted by ClimeCo Corporation pertaining to the following: - The utility and necessity of the invalidation provisions, as well as alternative approaches to offset integrity adopted by other jurisdictions. - All points related to regulatory compliance, its extra-jurisdictional nature, its need to be defined and interpreted narrowly and appropriately, and the need for violations to affect only the offsets attributable to the timing of the violation rather than the entire reporting during which the violation occurred. - Recommendations for improvements to general processes, including "wet signatures," materiality and timing of verification work. Thank you very much for your consideration.
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Date and Time Comment Was Submitted: 2016-03-11 10:30:17
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