On June 9, 2009 AGA submitted comments on EPA’s proposed rule on the mandatory reporting of greenhouse gas (GHG) emissions. The comments note AGA's support of the proposed reporting threshold of 25,000 tons per year of CO2-equivalent GHG emissions from large facilities in all sectors. AGA detailed the practical problems that would arise from the proposed daily metering and annual calibration requirements. In addition, AGA noted that EPA verification has worked well in other
Clean Air Act programs; third party verification should not be considered, as it is wasteful, expensive and would not appreciably improve the quality or reliability of GHG emissions reports.
The comments are posted under Environmental Comments and can be accessed by clicking here.