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The Proposed Rule of the California Air Resource Board (17 CCR
950101 et seq) would require some geothermal operators (those
emitting > 25,000 MT CO2e) to annually provide third-party verified
compliance data despite their being without a compliance
obligation.  Meeting these new requirements will add significant
expenses to these operators, costing each reporting unit tens of
thousands of dollars annually, without any corresponding benefits
to the environment given that any reasonable alternative to
geothermal power generation would significant increase the
emissions produced.
We would urge CARB to modify this proposal and either remove the
requirement for independent third-party verification or return to a
3- year verification requirement for these geothermal operators.