ECSI Blog

Here is the text of the USEPA’s response to our comments on their mandatory inventory rule.  This is not what we had hoped for but a least we were able to provide our viewpoint. 

Commenter Name: Kevin A. Lehner

Commenter Affiliation: Environmental Compliance Systems, Inc.

Document Control Number: EPA-HQ-OAR-2008-0508-0673

Comment Excerpt Number: 1

Comment: With regard to verification of inventory reports we believe USEPA has overlooked an important potential option and should review this option before selecting their final method for performing inventory reporting and verification activities. We believe USEPA should consider allowing reporters the option to either report directly to USEPA or to provide inventory reports verified by ANSI accredited ISO 14065 Verification and Validation Bodies through existing voluntary reporting organizations such as The Climate Registry. We believe that a thorough evaluation of this additional option for reporting and verification of inventory reports would show that most of the negative consequences of each of the three potential reporting options considered by USEPA could be avoided if this alternate approach were adopted by USEPA. With little additional effort, most voluntary GHG registries can adapt their reporting protocol to accommodate USEPA reporting requirements and emission calculation methods and transmit the data to US EPA on behalf of the reporter in a format acceptable to USEPA. USEPA would simply need to verify that the registries reporting protocol was consistent with USEPA’s and that the data reporting methods were in a format that could be easily accepted into USEPA’s recordkeeping and data analysis systems. Benefits of this alternate approach include; elimination of duplication of reporting by organizations already providing their inventories to the voluntary registries, overall reductions in effort and cost to USEPA for verification activities, higher stakeholder confidence in the accuracy of the inventory reports and, the flexibility for reporters to choose how they will transact required reports with USEPA.

Response: During the development of the rule, EPA considered a number of different options for verification of the reported data. EPA selected the self certification with EPA verification approach based on a number of factors that are discussed in detail in Section II.N of the preamble. Although we considered the hybrid approach suggested by commenter, we concluded this approach would not meet the needs of this program. First, in order to be relevant and applicable to the unique scope and specific requirements of this reporting rule, verification and accreditation systems would require substantial customization to this rule. Most programs that adopted a third party verification approach (e.g., CARB) found that they had to adapt existing programs to meet the specific needs of their program. Second, a reporting program with two or more different methods of verification would be more difficult to administer and place a greater burden on EPA resources. Third, receipt of emissions data from reporters selecting third party verification would likely be delayed due to the extra time required for third party verification. EPA has determined that direct submittal to EPA of annual emissions information and the data necessary to verify emissions will best ensure the availability of consistent, verified data for use in a timely fashion. EPA intends to work with the States to develop an efficient and timely system to share data and reduce the burden on reporters. See the preamble for the full responses on the emissions verification approach, the role of States, and relationship of this rule to other programs. For the memorandum “Review of Verification Systems in Environmental Reporting Programs” (EPA-HQ-OAR-2008-0508-047)