INGAA Comments Regarding the GHG Global Warming Potential Proposed Revisions

1. INGAA Supports Revisions to Table A-1 Global Warming Potentials Based on Current Best Science from the IPCC Fourth Assessment Report.











7. The rule should clearly indicate that GWP revisions only apply prospectively for applicability and permitting determinations associated with PSD and Title V permitting.


6. EPA Should Not Revise Table C-1 Heating Value and Emission Factor Values for Natural Gas. The Proposed Changes are Trivial and EPA Should Establish Data Quality Goals so that Immaterial Revisions are Not Introduced.

5. For New Reporters, EPA Should Provide Additional Flexibility and Clarity Regarding the Use of BAMM. The Proposed Subpart A BAMM Provisions Should Provide Necessary Flexibility and Be Clarified to Avoid Conflict with Subpart W BAMM Criteria.

4. INGAA Supports EPA’s Plan to Defer Reporting until the 2014 Reporting Year for Facilities that Become Subject to Reporting Due to GWP Increases.

3. EPA Should Define and Implement a Simple Process Using e-GGRT Notices and Messages to Inform Reporters of Revisions to Previous Year’s Reported Values and Log Reporter Comments Regarding Errors.

2. INGAA Supports EPA’s Plans to Revise Emissions in 2010 – 2012 Annual Reports. However, Reporters Must Be Able to Comment on the Revised Values.

INGAA Comments: