Proposed Rule Subpart DD and SS: Mandatory Reporting of Greenhouse Gas Emissions 

Meeting Documentation Date Staff Contact 

Information (Name, email, phone #) 

Name of Organization (Attach list of all attendees names and emails if possible) 

Summary of Discussion (e.g., applicability, 

reporting requirements, etc.)

Written ComProvided? Did they also submit to Do

6/3/2010 Sally Rand, 

Rand.Sally@epa.gov

202-343-9739 

Members of NEMA Ad-Hoc task group on SF6 and Partners of EPA’s SF6 Emission Reduction Partnership of Electric Power Systems List of attendees included:* Jamie Kurland - San Diego Gas and Electric Andy McCabe - AEP Mary Archer - Florida Power and Light Ken Boyd - Southern Company Todd Irwin - Areva Joe Durante - Mitsubishi Fred Blood - Austin Power Heather Crandell - ITC Bob Muller - Air Gas Mitch Contraras - Center Point Energy John Bigi - Duquesne Eric Hsieh - NEMA Theo Theodorou - Con Ed Anastasia O'Malley - Con Ed Sally Rand – EPA Mollie Averyt, - ICF International Paul Stewart – ICF International *List may not be comprehensive. 

Sally Rand, EPA, moderated conference call 

between manufacturers of equipment that are covered under subpart SS (manufacture of electrical T&D equipment) and Partners of EPA’s SF6 Emission Reduction Partnership of Electric Power Systems, covered under subpart DD (use of electrical T&D equipment) of the Proposed Amendment to the Greenhouse Gas Mandatory Reporting Rule. Discussion centered on: 

1. Reporting responsibilities during 

installation of equipment at customer sites 

NEMA suggested that the reporting requirement should fall under Subpart DD at the instant the equipment or gas physically enters the utility premises. (The "Premises" handoff) An alternative handoff mechanism would have the reporting requirement transfer to the utility at the point in time when the equipment warranty is activated and the title is transferred. (The "Title" handoff) For equipment that is shipped in an assembled state, the premises handoff makes sense, as the equipment may be stored for a period of months and is ultimately installed by utility personnel. In this case the premises handoff coincides with the title handoff. For equipment that the manufacturer assembles 

Yes, commensubsequently submitted to docket on botopics, see: EPA-HQ-OA2009-0927-0and EPA-HQOAR-2009-00081 (SoutheCompany); EHQ-OAR-200927-008 (OEPA-HQ-OA2009-0927-0(National GriEPA-HQ-OA2009-0927-0(Exelon Corporation)EPA-HQ-OA2009-0927-0(The Clean EGroup); EPAOAR-2009-00098 (NexterEnergy, Inc.)EPA-HQ-OA2009-0927-0(NEMA); EPHQ-OAR-200927-0126 (P
Date Staff Contact 

Information (Name, email, phone #) 

Name of Organization (Attach list of all attendees names and emails if possible) 

Summary of Discussion (e.g., applicability, 

reporting requirements, etc.)

Written ComProvided? Did they also submit to Do

onsite, utilities would prefer that the reporting responsibility remain with the manufacturer until final acceptance. In this case the premises condition would be satisfied before the title condition. Ideally the group could find a suitable handoff event that would clearly demarcate the reporting responsibility, whether utilizing the premises boundary, the title transfer, or some alternate combination. 

2. Certification of volume of gas contained 

inside delivered equipment 

EPA had requested comment on the need to certify the volume of gas contained inside delivered equipment. Some manufacturers and utilities indicated that the gas volume is commonly documented while others indicated that this data would create a new process and burden. Participants on the call appeared to be amenable to a codification of a best practice, namely the documentation of gas quantity inside equipment. Different means of reporting was discussed including by weight or some combination of weight, temperature and pressure. 

Holdings, Inc