Jul 21, 2023 2023 IPAA Comments on Supplemental Greenhouse Gas Reporting Rule Proposal
“These IPAA comments will focus on proposed Subpart B (Energy Consumption). The Environmental Protection Agency (EPA) argues that its initiation of Subpart B is:
…to improve the completeness of the data collected under the GHGRP, add to the EPA’s understanding of GHG data, and to better inform future EPA policy under the CAA, such as informing potential future EPA actions with respect to GHGs. Once collected, such data would also be available to improve on the estimates provided in the Inventory, by providing more information on the allocation of electricity use to different end use sectors.
In fact, it does not collect information on greenhouse gas (GHG) emissions. Instead, it requires operators to collect and submit information on the electricity and thermal energy used. Not only does this new Subpart effectively make these operators meter readers, it also misdirects their resources to obtain information far more readily available from electricity and thermal energy suppliers. From IPAA’s perspective it does not provide GHG emissions information because, for example, the electric energy source could be composited from numerous types of generation options. …”
In addition to the specific comments made herein, IPAA has joined comments submitted separately by the American Petroleum Institute (API).
