![](media/image1.wmf){width="0.65625in" height="0.65625in"}

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Schering-Plough Corporation

Global Supply Chain

1095 Morris Avenue

Union, New Jersey 07083-7143

Telephone (908) 298-4000

June 8, 2005

Mark Friedrichs, PI-40

Office of Policy and International Affairs

U.S. Department of Energy

1000 Independence Ave., S.W.

Washington D.C. 20585

Re: RIN 1901-!B11

> Draft U.S. Department of Energy Guidelines for Voluntary Greenhouse
> Gas Reporting.

Dear Mr. Friedrichs:

Schering-Plough appreciates the opportunity to comment on the Department
of Energy's 1605(b) program and we support a voluntary program for
greenhouse gas reporting. Schering-Plough is a global science-based
health care company with leading prescription, consumer and animal
health products. Through internal research and collaborations with
partners, Schering-Plough discovers, develops, manufactures and markets
advanced drug therapies to meet important medical needs.
Schering-Plough's vision is to earn trust of the physicians, patients
and customers served by its more than 30,000 people around the world.

We believe increased entity reporting would mark a successful 1605(b)
program. To achieve this goal, the Department of Energy (DOE) should
encourage expanded reporting on the current model instead of emphasizing
emission inventory registration. Registration is costly, time consuming,
and discourages voluntary use. As a global company, we have European
facilities covered under European Union (EU) Directive 2003/87/EC and EU
Guidance 2004/156/EC. In some ways, the voluntary 1605(b) program
exceeds European Union (EU) requirements and discourages registration
for the following reasons:

-   The EU limits emission inventories to 'installations' (i.e.
    facilities) of a certain size (Directive 2003/87/EC Annex I). If all
    of our company's facilities were covered under this directive, only
    25% would require registration. In contrast, 1605(b) would require
    at least 75% of our facilities to register, with the remaining sites
    falling under the allowed 3% emission exemption. This is a three
    fold expenditure of time, money, and effort.

-   The EU only requires registration of direct emissions. 1605(b)
    desires registration of direct, indirect, and other (i.e. mobile
    source) emissions.

-   The EU allows greater use of country emission factors, depending on
    an 'installation's' size. 1605(b) emphasizes direct emission
    measurements or analysis of fuel purchased which is more effort.

If DOE insists on promoting registration as the preferred reporting
method, it should follow EU requirements. This would limit the
registration effort and improve 1605(b) credibility by following an
established standard. This would not be difficult to implement as many
elements are similar and easily modified.

In addition, we offer the following additional comments unrelated to the
above:

-   A licensed professional engineer should be allowed to verify the
    emissions registered.

-   There are no indirect emission factors established for Puerto Rico
    where many pharmaceutical facilities are located.

-   Intensity should be based on an economic factor such as sales
    instead of product output. The latter metric is too diversified, is
    considered at times to be confidential business information, and not
    easily defined for corporate research sites or diversified
    manufacturers. Furthermore, we believe an economic factor better
    reflects the President's intent in emphasizing economic efficiency.

Should you have any further questions or comments on the above, we would
welcome any inquiries by contacting me at the above address or calling
Daniel Caramagno of my staff at (908)629-3781.

Respectfully submitted,

Michael Minerva

Director, Global Environmental Technical Services

and Compliance Support

bcc Russ Cerchiaro

Michael Minerva

Gus Moffitt