Further to last week’s update, the Society, together with a broader coalition of industry and trade organizations, submitted this joint letter to CARB on April 13, the public docket deadline, regarding the timing for stakeholder input following CARB’s March 23 SB 253 workshop.
As set forth in the letter, stakeholders continue to have significant concerns that the three-week comment period does not provide sufficient time to develop meaningful input on the complex and highly technical issues presented at the workshop, including Scope 1, Scope 2, and Scope 3 reporting approaches, greenhouse gas accounting methodologies, assurance frameworks, and cost considerations.
Noting continued uncertainty regarding CARB’s statements that “informal comments” will be accepted after April 13, the letter reiterates the request previously made by the Society and BPI that CARB provide express confirmation that it will review and meaningfully consider stakeholder input (including formal comment letters) submitted on or before June 1, prior to initiating formal rulemaking.
Stay tuned for further developments.
This post first appeared in the weekly Society Alert!