EPA's greenhouse gas rule ammendments

On November 9, 2011, the U.S. Environmental Protection Agency finalized technical corrections and other clarifying amendments to seven subparts under the Greenhouse Gas Reporting Rule (40 CFR part 98). In this action, EPA amended 40 CFR part 98 to correct technical and editorial errors and to address certain issues identified as a result of working with entities required to report during rule implementation and outreach. In general, these amendments do not change the overall requirements of the rule but improve clarity and ensure consistency across the calculation, monitoring and data reporting requirements. In addition, EPA has provided a one-time extension of the reporting deadline to September 28, 2012 for any entity that reports under the following source categories:
  • Electronics Manufacturing (Subpart I)
  • Fluorinated Gas Production (Subpart L)
  • Magnesium Production (Subpart T)
  • Petroleum and Natural Gas Systems (Subpart W)
  • Use of Electric Transmission and Distribution Equipment (Subpart DD)
  • Underground Coal Mines (Subpart FF)
  • Industrial Wastewater Treatment (Subpart II)
  • Imports and Exports of Equipment Pre–charged with Fluorinated GHGs or Containing Fluorinated GHGs in Closed–cell Foams (Subpart QQ)
  • Carbon Dioxide Injection and Geologic Sequestration (Subpart RR)
  • Manufacture of Electric Transmission and Distribution (subpart SS)
  • Industrial Waste Landfills (Subpart TT) and;
  • Injection of Carbon Dioxide (Subpart UU)

2011 is the first year for data collection for these subparts. As such, EPA is extending the reporting deadline to ensure that there is sufficient time for development and stakeholder testing of the electronic GHG reporting tool for these subparts.
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Sometime....less is better

One of the attorneys I met on LinkedIn - Barry Trilling - posted this little story. I am reproducing it here as a great teachable moment.
During the French revolution three prominent, but very unfortunate, professionals were condemned to beheading by the guillotine: a priest, a doctor, and an engineer. The three were conveyed to the scaffold together in an old ox cart and were marched up to the guillotine together amidst amass of cheering blood thirsty spectators. The priest was the first to meet his fate. The executioner very politely asked the priest if he preferred to avoid seeing the blade fall by lying face down rather than face up. The priest replied, "I've led a good life, have nothing to regret, and want to meet my maker face-to-face." So the priest lied down facing the blade. The executioner pulled the cord releasing the blade and it plummeted toward the priest's exposed neck. But within a half inch of reaching its fatal destination the blade stopped literally in its tracks. The crowd roared with delight and many of the onlookers fell to their knees in prayer. Not wanting to put any victim to double jeopardy the authorities released the priest, to the great delight of the crowd.
Then came the doctor's turn. He was asked the same question and thought "if it worked for the priest maybe it will work for me too," so he requested to take the blade face up. Again the blade stopped a half inch from the target, and as with the priest, the authorities released the doctor. Now was the engineer's turn and, being no one's fool, he also opted to take the blade face up. As he lay with his neck firmly placed in the crook of the guillotine and looked up to his maker, and to the blade, he exclaimed, "Ooh, I think I see your problem."
Moral of the story: Only answer the question that's asked, and don't volunteer information, your neck may be at stake, and in the case of this discussion, your client's neck!
Remember this story next time when you are being deposed or when you are speaking with an inspector.
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