Pfa proposed 'Comparable Alternative' criteria, as addressed by the referenced action. The background story is that the IAWG drafted and approved for publication these criteria approx. two years ago. Persons within the ARB strongly recommended that the criteria were not published since the entitlement for presenting a Comp.Alt lay with Fed agencies, and so the criteria were parked. My understanding (second-hand) is that there have been some Approval applications that have been presented to the ARB and Approved, though how the Comp.Alt was addressed was not consistent. I was then involved in an assessment for a client who, operating obo a Fed agency, was basically told to implement a Comp.Alt, so I dusted-off the criteria, inserted them into the SoCA/SoC and assessed against them. As I understand it the ARB were comfortable with those criteria being used and recognized that having them widely available would provide a consistent basis across all Approval scheme assessments, if these criteria were invoked. SO .. here they are, I think that the IAWG should review them again, given the time since they were first punted, and I'd be happy for them to be enhanced if that's what they need, but I'd then like to see them put through the publication process asap. I would consider them to be material and therefore requiring a 45-day public review. Clearly, if formalized within the 63A_SAC, some of the commentary (e.g. "Assessor introduced criterion") needs removal or modification. Pls note the date on this doc - that's how long this has been lingering without getting published. Let's get it done. Richard G. WILSHER CEO & Founder, Zygma Inc. www.Zygma.biz +1 714 797 9942