| First Name | David |
|---|---|
| Last Name | Armstrong |
| Email Address | armstrong3@llnl.gov |
| Affiliation | Lawrence Livermore National Laboratory |
| Subject | October 19, 2007 Draft Mandatory Reporting of GHG Emissions |
| Comment | Request changing Section 95101 "Applicability" as follows: 1. Change subsection (b)(8) from "Operators of other facilities..." to "Operators of other industrial facilities..." 2. Change subsection (c) to add a new item: "(5) Sources that are solely used for comfort heating." Rationale: The staff report for the subject rulemaking states on page 4 that, "under the proposed regulation, the facilities that are required to annually report their GHG emissions include...industrial sources that emit over 25,000 metric tonnes per year of CO2." However in the draft subsection (b)(8), the word "industrial" was omitted. There are some non-industrial facilities that may exceed the reporting threshold based on emissions from comfort heating. Hospitals and schools have already been excluded for this reason, but there are other facilities that should be excluded for the same reason. Also in this regard, please note on page 14 of the staff report, Section 5, "Defining a "Facility" and an "Operator", which states "...unspecified sources such as residential heating and cooling would not be included." |
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| Date and Time Comment Was Submitted | 2007-11-09 15:58:49 |
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