I understand from 75 FR 81350 (2010) that you seek further information about the impact of the public availability of EPA emissions information, in particular (a) how public disclosure might relate to competitive disadvantage and (b) whether certain EPA-required information might already be available from other publicly available data.
My submission based on my research* in the area speaks to both these issues. I also comment briefly on a third issue, namely, the relation of the EPA-required disclosures to the present public company disclosure framework.
I have uploaded my full submission as a separate file.
*Griffin, Paul A., Lont, David H. and Sun, Yuan. 2011. The Relevance to Investors of Greenhouse Gas Emission Disclosures. UC Davis Graduate School of Management Research Paper No. 01-11, January 5, 2011.
Attachments:
Comment attachment submitted by Paul A. Griffin, Professor of Management, University of California, Davis
Title: Comment attachment submitted by Paul A. Griffin, Professor of Management, University of California, Davis
Comment submitted by Paul A. Griffin, Professor of Management, University of California, Davis
This is comment on Proposed Rule
Change to the Reporting Date for Certain Data Elements Required Under the Mandatory Reporting of Greenhouse Gases Rule; Proposed rule
View Comment
Attachments:
Comment attachment submitted by Paul A. Griffin, Professor of Management, University of California, Davis
Title:
Comment attachment submitted by Paul A. Griffin, Professor of Management, University of California, Davis
Related Comments
View AllPublic Submission Posted: 01/11/2011 ID: EPA-HQ-OAR-2010-0929-0004
Mar 07,2011 11:59 PM ET
Public Submission Posted: 01/24/2011 ID: EPA-HQ-OAR-2010-0929-0006
Mar 07,2011 11:59 PM ET
Public Submission Posted: 02/08/2011 ID: EPA-HQ-OAR-2010-0929-0010
Mar 07,2011 11:59 PM ET
Public Submission Posted: 02/10/2011 ID: EPA-HQ-OAR-2010-0929-0011
Mar 07,2011 11:59 PM ET
Public Submission Posted: 02/25/2011 ID: EPA-HQ-OAR-2010-0929-0012
Mar 07,2011 11:59 PM ET