Petition For Reconsideration

This petition voices objections that could not have been raised during the public comment period because they concern Final Rule provisions that did not appear in the proposed rule, 74 Fed. Reg. 16448 (April 10, 2009) (the “Proposed Rule”). Each of INGAA’s first three concerns deal with regulations allowing operators to compute greenhouse gas (“GHG”) emissions using “best alternative monitoring methods” (“BAMM”) in lieu of the methods prescribed elsewhere in Subpart W of EPA’s GHG reporting regulations. The BAMM regulations were not part of Proposed Rule, and there was no reasonable basis for INGAA to anticipate their issuance. Also, as noted in INGAA’s fourth item for reconsideration, the Final Rule raises implementation issues that were not evident in the Proposed Rule because they relate to previously unannounced requirements for emissions estimation and reporting.