INGAA believes EPA clearly and transparently should explain all changes to the methodology it relies upon to arrive at its National Inventory. All stakeholders should have the ability to understand the reason for any increases or decreases to the level of the National Inventory and changes attributable to the various sectors. INGAA recommends that EPA revise the Planned Improvements section of the Draft GHG Report to define how EPA plans to integrate additional data, including Subpart W data, into its National Inventory, with a goal to use updated emission factors in the 2016 annual National Inventory report. EPA should work with all stakeholders, including INGAA, on this effort. A more accurate and timely National Inventory will help regulators, the industry and the public understand the GHG Inventory and sources of emissions.
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