Submitted Comment Name Simin Mehrabani Affiliation N/A Subject Third-Party Assurance Frameworks and Verifier Eligibility under SB 253 Message Dear CARB SB 253 Rulemaking Team, Thank you for the opportunity to provide comments regarding the proposed third-party assurance framework under SB 253. I appreciate CARB’s indication during the public workshop process that it is considering a standards-based approach for assurance engagements rather than establishing a separate CARB accreditation program for assurance providers. However, additional clarification is needed regarding whether assurance providers must obtain formal accreditation, certification, or licensing under one of the listed assurance frameworks themselves (e.g., ISO accreditation pathways), or whether assurance providers may perform engagements so long as they conduct the work in accordance with the listed standards. I encourage CARB to carefully consider the substantial cost and administrative burden associated with requiring formal accreditation under assurance frameworks. For many qualified greenhouse gas assurance professionals, particularly existing CARB-accredited Lead Verifiers under the LCFS and Mandatory Reporting Regulation (MRR) programs, requiring additional external accreditation may create unnecessary duplication without materially improving assurance quality. CARB’s LCFS and MRR verifier programs already require extensive competency demonstration, conflict-of-interest safeguards, sector expertise, continuing education, and familiarity with greenhouse gas quantification and verification principles. These programs are already substantially aligned with ISO-based verification concepts. Accordingly, I encourage CARB to consider adopting one of the following approaches: 1. Permit assurance providers to conduct SB 253 assurance engagements if they certify that the engagement was performed in accordance with one of the listed assurance standards, without requiring separate formal accreditation under that framework; or 2. Explicitly recognize existing CARB-accredited LCFS and/or MRR Lead Verifiers as qualified to perform assurance engagements conducted under ISO 14064-3 and related ISO verifier qualification standards, without requiring duplicative ISO accreditation processes. Providing this flexibility would: • reduce unnecessary compliance costs, • avoid limiting the available pool of qualified assurance providers, • support market capacity during SB 253 implementation, • and maintain assurance quality through adherence to recognized standards and existing professional competency requirements. I respectfully request that CARB clarify this issue expressly in the final rulemaking language and supporting guidance to avoid uncertainty for assurance providers and reporting entities. Thank you for your consideration. Sincerely, Simin Mehrabani File Upload (i.e., Attachments): N/A N/A
Información del envío