The following comments from Sunoco, Inc. refer to the document made
available at the 12/5/2003 Public Hearing, entitled "Voluntary Reporting
of Greenhouse Gases (1605b) Program -- Proposed Revision of General
Guidelines -- Federal Register Vol. 68, No. 234, Pages: 68204-68231 --
Department of Energy 10CFR Part 300 RIN 1901-AB11 -- December 5, 2003"

-   II.B -- page 14 -- Should Trade associations be allowed to report
    for an industry? We are concerned that this has the potential to
    compromise the credibility of industry data. Unless the industry
    report's scope is clearly stated, including naming the companies
    included in the inventory estimate, and those companies included
    agree, through some sort of certification process, that their
    emissions have been correctly represented, this type of filing will
    be suspect. Also, if a company wishes to go on the record
    individually, in order to record or register their inventory, it is
    difficult to see how it could be done through the trade association
    mechanism. If trade association reporting is allowed, it must be
    clear who is in, who is out, and whether of not a reporter is also
    filing separately.

-   II.D -- page 16 -- Registration of other gases/solids that may have
    significant, quantifiable effects? We support including the
    capability of including other substances with significant climate
    impact. Registration should be afforded those covered by Technical
    Guidelines. Others, for which Guidelines do not exist, should be
    recordable, and convertible to Registered status once Technical
    Guidelines are created.

-   II.H.1 -- page 20 -- Reduction in emissions intensity. The
    definition of "changes in products" is significant to Sunoco. The
    petroleum industry is adding processing capability to meet federally
    mandated fuels requirements. These new processes will consume energy
    without increasing additional product, raising our energy and GHG
    intensities. Unless the definition of "change of products" or some
    other mechanism allows us to redefine our products to compensate for
    this, we will show intensity increases that will reduce the impact
    of our positive actions.

-   II.I -- page 23 -- Should independent verification be required of
    all reports? We feel independent verification should not be required
    for voluntary reporting. The system perhaps should require that
    sufficient documentation be identified and maintained so that the
    results could be audited. There is no need in a voluntary reporting
    system to have mandatory auditing. Senior officer signoff is
    sufficient. Anyone selling reduction credits will have to comply
    with the requirements of the marketplace. Those not trading should
    not need to.

-   II.L -- page 25 -- Registration of reductions only after 2002. We
    disagree. While the President's program covers the period 2002-2012,
    other current or possible future programs may well allow/require the
    use of another base year. We recommend that the option to grant the
    same credibility to a reporter's pre-2002 data, if the Reporter is
    able to meet the same reporting requirements, should be included. We
    feel strongly that our 1990 to 2002 performance, currently part of
    the 1605b record, is or could be brought to the same standards as
    current reporting. If we can attest to that level of quality, our
    data should be granted the same level of credibility.

-   II.O.2 -- page 28 -- Exclusion of certain small emissions. We are
    concerned that this exclusion can be misinterpreted or misapplied.
    It would be acceptable to exclude any unique emission source
    estimated to be less than 10,000 tons, but not to allow the
    exclusion of a set of emission sources, each less than 10,000 tons.
    A company may have a chain of operations, each emitting 9,999 tons
    per year. The exclusion should not apply in a case like this.

-   II.O.6 -- page 32 -- Recognizing Emissions Offsets. Could there be
    some provision for the application of a new, lower GHG Intensity
    process by one entity which causes the shutdown of a older, higher
    GHG Intensity process owned or operated by another entity? We may
    have such a process. The benefit to the environment is clear, but on
    either an absolute or intensity basis, the addition of a new process
    is an increase. The ability to offset the addition with a reduction
    elsewhere seems like an appropriate approach, but if the other
    entity is not a reporter, it's not clear how it could be
    accomplished./

-   II.O.8 -- page 36 -- The merits of using the 1605b program for other
    documentation. We support making the 1605b program the standard
    reporting mechanism for any Federal program related to GHG emissions
    reductions

Contact:

Don Verdiani

Corporate Projects Manager

Sunoco, Inc.

1801 Market Street

Philadelphia, PA 19103-0699

215-977-6271 office

215-246-8313 fax

dlverdiani@sunocoinc.com