Comment Log Display

Thank you for the opportunity to submit comments on the recent
workshop regarding proposed amendments to the MRR and cap-and-trade
rules. In short, under the the proposed deadline, it would be very
challenging to provide quality verification services.

First, regarding the June 1 reporting deadline for EPEs, I do not
feel that there is enough time between June 1 and the proposed
August 1 verification deadline to adequately verify Electric Power
Entities (EPEs) reports. Rajinder indicated that EPEs could always
submit earlier and start the verification earlier. While that is
true, presumably there is a reason why the EPE reports were due so
late, e.g., data not being available earlier in the year. I recall
that many do not have RECs retired until sometime in July. I
imagine you are working on this aspect of things. I am simply
concerned that while some will submit early, perhaps many EPEs
cannot or will not, and that would not leave an adequate amount of
time to do a good verification, and in fact may make it difficult
for a reporter to find a verifier willing to take on the
verification on that schedule.

On a practical level, one thing that CARB should be aware of is
that it is often very difficult to get quick turnaround from
reporters on answering questions in June and July. Extremely
difficult. Invariably, several key staff members are on vacation
for a week or two at a time each. I realize the hope is that this
would change if the regulatory deadline were moved, but the
practical realities should be taken into account, to foresee and
avoid the potential problems with a rule change.

Following up on Rajinder’s discussion of the procedure on CARB’s
end after verifications are submitted, CARB might consider running
its QA/QC routines on the reports as soon as they are submitted,
rather than waiting until after the verification. That would be
helpful to all parties, and that way any “red flags” can be passed
along to the verifiers at the beginning of the process to
investigate, rather than waiting to catch problems afterward.

I would recommend staggering the site visit requirement in the
regulation so that not every facility is required to have a site
visit in the first year of the compliance period. That adds yet
another time pressure to the system, which would make it difficult
to handle an August 1 deadline in those years. Perhaps you could
allow the site visit to be delayed by a year or two if the reporter
is using the same VB as previous years, and that VB has already
performed a site visit. Or allow site visits before the report is
submitted.

You may want to add a provision to allow exemptions from the site
visit requirement with approval from CARB. While the site visit is
valuable, or even essential, for some facilities, for others it it
pretty pointless. Most notably, for some electricity
importers/exporters and transportation fuel suppliers, the critical
verification activity is reviewing databases and contracts, and
there is nothing that is done onsite that could not be done just as
effectively via phone or computer conference (for example, using
GoToMeeting to allow the reporter to demonstrate the data system).
Often these entities are based out of state as well, which
needlessly inflates the expense of the verification to the
reporter. 

If you’d like to streamline the verification timeline, I would
strongly suggest that CARB carefully consider and prioritize the
reported data to focus and limit the scope of the verifications to
certain types of data that are absolutely critical. The scope and
work load has grown quite a bit over the course of the program,
from basically just checking the accuracy and precision of data
directly associated with the emissions at first, to now checking
essentially every data point submitted. Is all of that really
necessary? If so, that’s fine, but recognize that it takes time and
effort. To achieve a quicker schedule, a more limited verification
scope would seem to be a reasonable trade-off.

Also, I would note that the single most frustrating element of the
verification process in our experience, both for the verifiers and
the reporters, is the requirement that every correctable error be
corrected. Because of that, our Issues Logs are often littered with
lots of very minor errors that have absolutely no consequences with
respect to the report. And these both frustrate (and frankly,
sometimes infuriate) the reporters and divert the focus from the
important issues that need to be addressed. Follow-up on these
super-minor issues eat up an disproportionate time of the
verification. It kind of goes to the comment that one gentleman
made in the meeting that 1% of the verification takes a large
portion of the time. I understand that CARB desires error-free
reports, but there should be a reasonable threshold for requiring
action, below which correction is not required. Where should that
threshold be set? I don’t know, but any threshold would be better
than the absolute that is now in place. Again, I think
prioritization is in order, if the schedule is to be compressed.

Thanks as always for your hard work and consideration. I look
forward to future workshops on the matter.

Regards,
Lara