Anonymous public comment

COMMENT for Docket ID No. EPA–HQ–OAR–2011–0147, 2011 Technical Corrections, Clarifying and Other Amendments to Certain Provisions of the Mandatory Reporting of Greenhouse Gases Rule The proposed revisions to Section 98.463(a)(2)(ii)(C) revise the definition of LFC and YrData to allow closed landfills that have some measurement data to appropriately calculate Wx only for years for which the closed landfill does not have waste disposal data available from company records or from Equation TT-3. Based on the proposed definition of YrData, it seems Equation TT-4 is intended to apply when missing data occurred up to a certain date, and then data was available for all subsequent years. However, if data is available for only some of the years, and data is missing for years prior to and after the dates the data is available for, this equation does not appear to accurately reflect the total waste disposal. For example, if a facility has a closed landfill and they know how much waste was placed in the landfill, and they have data for 3 years, but do not have data for 5 years before and 5 years after that data, and Equation TT-4 is applied, the sum of the total waste disposed (by adding the known annual disposal quantity data to the calculated annual disposal quantity data from Equation TT-4) could be higher or lower than what was actually disposed. In this circumstance, it seems the most accurate method would be to use actual data for the years it was available, subtract that from the total waste disposed, and then evenly distribute the remaining waste disposed over the years when data was not available. This would provide a total waste when all years were added together that matched the total waste that was present when the landfill was closed.