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EPA Proposed Greenhouse Gas Registry

  • 1.  EPA Proposed Greenhouse Gas Registry

    Posted 04-15-2009 19:55
    Dear Colleagues - Here's information on a webcast we are hosting later this month, hoping to attract a broad corporate audience and financial analysts - happy to have academics also! THe question of facility/parent company is critical and something I have been working on for some time in the context of making EPA information more user friendly for the financial services industry in connection with the NY Society for Security Analysts. This issue ALWAYS comes up. EPA response has thus far been lackluster, though the number of people convinced that this needs to happen is growing. We've been able to gain some good allies. If EPA hears from another stakeholder group that this is critical, we hope it will stoke the fire under their feet to move on this. Perhaps in the context of a major new EPA database we can push this important agenda forward. In a recent phonecall with EPA it became clear to me that the folks (primarily in the Office of Air) who are fronting the GHG reporting rule effort have little idea of the desire to have corporate level information. You can comment via the Federal Register! So please do your part to get this solidly on the agenda.

    Dinah Koehler
    Conference Board

    *****************************************************************************

    PREPARING FOR MANDATORY GREENHOUSE GAS REPORTING IN THE U.S.

    A Dialogue with the Environmental Protection Agency

    Webcast Hosted by The Conference Board

    Date: April 29, 2009

    Time: 2:00 PM – 3:00 PM (ET)

    Panelist: William N. Irving, Chief of the Program Integration Branch. U.S. Environmental Protection Agency, Climate Change Division. This EPA branch is responsible for preparing the annual Inventory of GHG Emissions & Sinks (submitted to the UN), analyzing climate legislation, supporting domestic and international climate policy development, and coordinating the EPA’s mandatory rulemaking for greenhouse gases. Mr. Irving is an elected member of the Intergovernmental Panel on Climate Change Task Force Bureau for GHG Inventories.



    Moderator: Dinah A. Koehler, Sc.D., Senior Research Associate, The Conference Board

    Government regulation of Greenhouse Gases (GHGs) in the U.S. is on its way. Last month, the U.S. Environmental Protection Agency released its proposed GHG Reporting Rule, which would require manufacturers, utilities, fuel suppliers and vehicle manufacturers to report their total annual GHG emissions starting in 2010.The rule covers up to 90% of GHG emissions sources in the U.S. In addition, the data generated by the rule will instruct a variety of new climate change policies under federal consideration, including cap and trade, regulation of GHG emissions under the Clean Air Act and carbon fees. Given the significance of this policy shift for all business, The Conference Board is presenting a webcast dialogue with the EPA to discuss specific aspects of the rule, and its implications for business including how the data can be used.

    This webcast will discuss:
    Whether companies currently doing reporting under a voluntary reporting scheme (e.g. Carbon Disclosure Project) need to change how they collect data
    How the rule addresses facility vs. company level reporting
    Coordination between filing to the EPA and the SEC, especially to satisfy investor interest in GHG emissions data
    How the data can help a company subject to a shareholder resolution on climate change or litigation
    How to comment on the rule
    Registration/Cost:

    There are different fee levels for this webcast: Conference Board members $250; non-members $350; non-profit employees $175.

    To register go to The Conference Board website (www.conference-board.org) and follow these links: about half way down the home page select Webcasts under Register Now!; then select the April 29 webcast, “Preparing for Mandatory Greenhouse Gas Reporting in the U.S.”


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    ________________________________________
    From: Organizations and the Natural Environment Discussion [ONE-L@AOMLISTS.PACE.EDU] On Behalf Of Barnett, Michael [mbarnett@coba.usf.edu]
    Sent: Wednesday, April 15, 2009 6:34 PM
    To: ONE-L@AOMLISTS.PACE.EDU
    Subject: Re: EPA Proposed Greenhouse Gas Registry - Please respond directly to me if interested

    Please see below.

    ***********************
    Michael L. Barnett, PhD
    University of South Florida
    College of Business Administration
    Department of Management & Organization
    4202 E. Fowler Avenue, BSN 3213
    Tampa, FL 33620-5500
    Phone: 813-974-1727
    Fax: 813-974-1734
    E-mail: mbarnett@coba.usf.edu<mailto:mbarnett@coba.usf.edu>
    Webpage: http://www.coba.usf.edu/barnett

    View my research on my SSRN Author page:
    <http://ssrn.com/author=414796>
    **************************************************
    ________________________________
    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
    1616 P Street NW
    Washington, DC 20036-1400
    cohen@rff.org; www.rff.org<http://www.rff.org/>
    (202) 328-5167

    Professor of Management and Law
    Vanderbilt University
    www.mba.vanderbilt.edu/faculty/mcohen.cfm<http://www.mba.vanderbilt.edu/faculty/mcohen.cfm>