I am in full support of the proposed rule covered in docket ID No. EPA-HQ-OAR-2008-0508. The revisions in this rulemaking, which according to the EPA website, would “provide additional clarification where Part 98 was vague or led to confusion among reporters, amend specific provisions related to certain issues identified as a result of working with the affected sources during rule implementation and outreach, [and would include] corrections to terms and definitions in equations and other technical corrections.” The revisions to the pertinent subparts, namely A, C, D, F, G, P, V, X, Y, AA, OO, and PP, would allow for clear-cut guidance on the regulation and would allow for better reporting through the EPA Greenhouse Gas Reporting Program (GHGRP). These regulations and reports will help businesses operate on a higher economically friendly level. As this is a world we all share, not only with other countries, but with future generations, the preservation of as much as possible is an imperative. On the topic of EPA verification of reported data, I also agree with what is in the docket. Even if the information has gone through a separate third-party verification process, I believe that it is the EPA’s job to verify to their own standards, although, as written in their statement to the EPA, the Glass Association of North America (“GANA”), clearly disagree. It seems like they are just trying to have less work on their plate. In that same statement, they also request to have the initial date of reporting changed, stating the “EPA underestimates the time the flat glass manufacturing industry requires to compile, verify, and review the annual data needed for submittal…” I do not believe the EPA needs to change the original date as specified in the plan. Keeping these original dates and keeping the EPA in charge of verification takes away opportunities for corruption or the manipulation of GHG numbers.
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This is comment on Proposed Rule
Mandatory Reporting of Greenhouse Gases
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