Please see below.
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Michael L. Barnett, PhD
<st1:place w:st="on"><st1:city w:st="on">University of South</st1:city> <st1:state w:st="on">Florida</st1:state></st1:place>
<st1:place w:st="on"><st1:placetype w:st="on">College</st1:placetype> of <st1:placename w:st="on">Business Administration</st1:placename></st1:place>
Department of Management & Organization
<st1:street w:st="on"><st1:address w:st="on">4202 E. Fowler Avenue</st1:address></st1:street>, BSN 3213
<st1:place w:st="on"><st1:city w:st="on">Tampa</st1:city>, <st1:state w:st="on">FL</st1:state> <st1:postalcode w:st="on">33620-5500</st1:postalcode></st1:place>
Phone: 813-974-1727
Fax: 813-974-1734
E-mail: mbarnett@coba.usf.edu
Webpage: http://www.coba.usf.edu/barnett
View my research on my SSRN Author page:
<http://ssrn.com/author=414796>
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From: Organizations and the Natural Environment Discussion [mailto:ONE-L@AOMLISTS.PACE.EDU] On Behalf Of Cohen, Mark
Sent: Wednesday, April 15, 2009 3:37 PM
To: ONE-L@AOMLISTS.PACE.EDU
Subject: EPA Proposed Greenhouse Gas Registry - Please respond directly to me if interested
The newly proposed U.S. EPA Greenhouse Gas Registry requires identification of facility, but not corporate parent. It seems to me that a simple requirement to include corporate parent (with appropriate definitions) would assist researchers, firms that aggregate and collate data for investors, and ultimately investors themselves.
I am interested in submitting a comment to EPA's Docket on this issue, and am soliciting your input on two issues:
(1) Do you have any additional thoughts on the value of this information, citations to articles, individuals, etc. that might be used in arguments to EPA?
I agree that it would be useful to researchers to have this information. For my dissertation, I conducted a longitudinal study that involved tracking hundreds of facility-level accidents to corporate parents over a 20-year window. This was necessary in order to determine the overall financial effects of these accidents. But it was very difficult to do, given that ownership (in the petrochemical industry in this case) of facilities changes frequently over time. The time and effort involved in such a project surely limits the number of such studies (and increases the cost). Moreover, the inability to find corporate parents in many cases leads to diminished sample size and so weakened and perhaps biased findings. Or even wrong findings, if the lineage is incorrect.
(2) Are you interested in signing such a letter? If so, I will send you a draft beforehand so that you can approve or decide not to sign.
For what it's worth, I think I'd be glad to do it.
(3) I am also concerned about the threshold for reporting - 25,000 tons instead of 10,000 tons that is normally mentioned in proposed legislation. This might be a separate letter/issue - but if you have any insights on this, let me know..
Both seem huge to me – not bright enough to have good insights there.
This needs to move quickly, as the comment period extends through approximately May 10.
Thanks!
You're welcome!
Mark
Mark A. Cohen
Vice President for Research and Senior Fellow
Resources for the Future
<st1:address w:st="on">1616 P Street NW</st1:address>
<st1:place w:st="on"><st1:city w:st="on">Washington</st1:city>, <st1:state w:st="on">DC</st1:state> <st1:postalcode w:st="on">20036-1400</st1:postalcode></st1:place>
cohen@rff.org; www.rff.org
(202) 328-5167
Professor of Management and Law
<st1:place w:st="on"><st1:placename w:st="on">Vanderbilt</st1:placename> <st1:placetype w:st="on">University</st1:placetype></st1:place>
www.mba.vanderbilt.edu/faculty/mcohen.cfm