Comment Log Display

At the February 24th workshop, the California Air Resources Board
proposed changing the MRR verification deadline from September 1 to
August 1 (Slide 8). 

First Environment is very concerned and does not support the
changing of the verification deadline, especially for EPEs, without
additional changes that will clearly facilitate meeting an earlier
deadline.  Our experience during previous verification years have
demonstrated that the verification process has taken until at least
mid-August.  Changing the deadline without making appropriate
changes to the MRR to facilitate meeting the deadline will
potentially result in a less impartial and/or rigorous verification
process, less accurate GHG reports submitted to ARB, and a higher
risk of missing the verification deadline for reporters which could
result in enforcement action.  Furthermore, it should be
acknowledged that an earlier verification deadline reduces the
performance period for our services and could produce a negative
effect on our California-based business. 

At the February 24th workshop, other changes to the MRR were
proposed as method of facilitating meeting the August 1 deadline
(slide 16).  It is unclear how the proposed changes would
facilitate meeting an earlier deadline and therefore do not support
implementing an earlier verification deadline.

To meet an earlier deadline, changes to the MRR must encourage the
verification process to begin sooner, either before or very shortly
after the reporting deadlines.  First Environment has several
suggestions regarding revisions that would facilitate this earlier
start.

First Environment proposes revising the MRR to introduce additional
interim deadlines for the reporter between the existing report
submission and the report verification deadlines.  These interim
deadlines could include, but are not limited to, a deadline for the
submission of a reporter’s COI form, conducting the verification
kickoff meeting, and/or performance of the site visit.  First
Environment believes this would encourage reporters and VBs to
begin the verification process earlier after report submission and
thereby facilitate verification completion by an earlier
verification deadline.  

First Environment also proposes revising the MRR to specify
reporters to upload key documents and records to the Cal e-GGRT
tool at the time of GHG report submission.   The documents and
records could include, but are not limited to, the monitoring plan,
fuel and energy purchase records, meter calibration records, and
other documents and records that are relevant to GHG report
verification.  Having these documents uploaded to Cal e-GGRT for
download by the reporter’s verification body will allow core 
verification activities to start more quickly. 

Without these revisions to the MRR, or other revisions to the MRR
that can clearly be demonstrate to facilitate meeting an earlier
verification deadline, First Environment requests that the
verification deadline remain September 1.