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Potential Topics for a Comment Letter for Steering Committee Review

Potential Topics for a Comment Letter for Steering Committee Review. TWG agreed to engage in a discussion at the Denver meeting in order to identify “topic comments” or “common ground” that might assist and/or form the basis for comment letters to EPA from:

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Potential Topics for a Comment Letter for Steering Committee Review

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  1. Potential Topics for a Comment Letter for Steering Committee Review • TWG agreed to engage in a discussion at the Denver meeting in order to identify “topic comments” or “common ground” that might assist and/or form the basis for comment letters to EPA from: • Steering Committee member organizations • TWG member organizations • Comments would be framed within the specific scope and charge of the TWG related to the O&G E&P sector

  2. TWG discussion items • Initial list of potential topic areas that the TWG might discuss • Support development of comments by Steering Committee members and TWG member organizations. • Starting point for the conversation • Next steps • Ross & Associates would then take the results of the discussions in Denver and advice received from the TWG to draft “topic comments” for the use of the Steering Committee members and TWG member organizations • The comments are due to EPA by June 9 to comply with the EPA’s requirements for comments (http://www.epa.gov/EPA-AIR/2009/April/Day-10/). 

  3. Potential Topics • Definition of facility •  O&G field – operational control • Scope of reporting • Direct (Scope 1) and Indirect (Scope 2) emissions for all significant sources of GHG emissions from O&G E&P operations.  Mobile source emissions will be included as Scope 1 emissions for equipment over which a reporter has operational control.

  4. Potential Topics, cont. • Emissions measurement approaches • Discuss range of confidence of emissions measurements (e.g. Methods of measuring emissions from combustion sources have a fairly high degree of confidence, while more work is needed to accurately identify methods for characterizing fugitive emissions (and the TWG might offer to help EPA) • Emissions data reporting • Interest in a transparent and consistent reporting approach that does not duplicate existing databases/reporting  

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