To: Regional Enforcement Division Directors and Coordinators
OCE Division Directors
cc. Regional Air Enforcement Branch Chiefs
Measures Review Board
OECA Office Directors
The attached guidance describes the process for reporting greenhouse gases (GHGs) for civil enforcement actions concluded in FY 2010. We appreciate the comments that the regions and headquarters offices provided on the August draft guidance. The draft guidance required an estimation of GHG reductions from cases after subtracting any obvious and noteworthy emissions increases. This “netting” calculation would have allowed for consideration of off-site emissions reductions in specific circumstances.
After review of the comments, we think that this approach is impractical for FY2010. Given the current state of our understanding of, and our ability to calculate, actual GHG reductions, we have substantially revised and simplified the guidance for FY2010 reporting. We will consider a more robust approach for GHG reductions reporting in FY2011.
We recommend each Region (and OCE where they are the case lead) report five to ten cases with noteworthy GHG reductions that can be simply calculated using the approach explained in the attached guidance. For national cases, or multi-regional cases, the lead region or OCE should report the GHG reductions. However, a Region may report more than ten cases if it wishes, or fewer than five cases if there are not that many cases with noteworthy GHG reductions that can be simply calculated in accordance with the guidance for FY2010.
Please manually report this GHG information consistent with the streamlined approach adopted in this guidance to Donna Inman by no later than October 29, 2010. This manual reporting deadline for GHG reductions does not modify the existing deadline for entering all other end-of-year data by October 13, 2010.
David A. Hindin, Deputy Director
Office of Compliance
U.S. Environmental Protection Agency
voice 202-564-1300; fax 202-564