Proposed Rule Subpart DD and SS: Mandatory Reporting of Greenhouse Gas EmissionsMeeting DocumentationDateStaff ContactInformation (Name,email, phone #)Name of Organization (Attachlist of all attendees names andemails if possible)Summary of Discussion(e.g., applicability,reporting requirements, etc.)Written CommentsProvided?Did they alsosubmit to Docket?Date sent toEPA- CCD6/3/2010Sally Rand,Rand.Sally@epa.gov202-343-9739Members of NEMA Ad-Hoctask group on SF6 and Partnersof EPA’s SF6 EmissionReduction Partnership ofElectric Power SystemsList of attendees included:*Jamie Kurland - San Diego Gasand ElectricAndy McCabe - AEPMary Archer - Florida Powerand LightKen Boyd - Southern CompanyTodd Irwin - ArevaJoe Durante - MitsubishiFred Blood - Austin PowerHeather Crandell - ITCBob Muller - Air GasMitch Contraras - Center PointEnergyJohn Bigi - DuquesneEric Hsieh - NEMATheo Theodorou - Con EdAnastasia O'Malley - Con EdSally Rand – EPAMollie Averyt, - ICFInternationalPaul Stewart – ICFInternational*List may not becomprehensive.Sally Rand, EPA, moderated conference callbetween manufacturers of equipment that arecovered under subpart SS (manufacture ofelectrical T&D equipment) and Partners ofEPA’s SF6 Emission Reduction Partnership ofElectric Power Systems, covered under subpartDD (use of electrical T&D equipment) of theProposed Amendment to the Greenhouse GasMandatory Reporting Rule.Discussion centered on:1.Reporting responsibilities duringinstallation of equipment at customer sitesNEMA suggested that the reportingrequirement should fall under Subpart DD atthe instant the equipment or gas physicallyenters the utility premises. (The "Premises"handoff)An alternative handoff mechanism would havethe reporting requirement transfer to the utilityat the point in time when the equipmentwarranty is activated and the title is transferred.(The "Title" handoff)For equipment that is shipped in an assembledstate, the premises handoff makes sense, as theequipment may be stored for a period of monthsand is ultimately installed by utility personnel.In this case the premises handoff coincides withthe title handoff.For equipment that the manufacturer assemblesYes, commentssubsequentlysubmitted to thedocket on bothtopics, see:EPA-HQ-OAR2009-0927-0075and EPA-HQOAR-2009-0927-0081 (SouthernCompany); EPAHQ-OAR-2009-0927-008 (Oncor);EPA-HQ-OAR2009-0927-0094(National Grid);EPA-HQ-OAR2009-0927-0096(ExelonCorporation);EPA-HQ-OAR2009-0927-0097(The Clean EnergyGroup); EPA-HQOAR-2009-0927-0098 (NexteraEnergy, Inc.);EPA-HQ-OAR2009-0927-0125(NEMA); EPAHQ-OAR-2009-0927-0126 (PepcoN/ADate Staff ContactInformation (Name,email, phone #)Name of Organization (Attachlist of all attendees names andemails if possible)Summary of Discussion(e.g., applicability,reporting requirements, etc.)Written CommentsProvided?Did they alsosubmit to Docket?Date sent toEPA- CCDonsite, utilities would prefer that the reportingresponsibility remain with the manufactureruntil final acceptance. In this case the premisescondition would be satisfied before the titlecondition.Ideally the group could find a suitable handoffevent that would clearly demarcate thereporting responsibility, whether utilizing thepremises boundary, the title transfer, or somealternate combination.2.Certification of volume of gas containedinside delivered equipmentEPA had requested comment on the need tocertify the volume of gas contained insidedelivered equipment. Some manufacturers andutilities indicated that the gas volume iscommonly documented while others indicatedthat this data would create a new process andburden. Participants on the call appeared to beamenable to a codification of a best practice,namely the documentation of gas quantityinside equipment. Different means of reportingwas discussed including by weight or somecombination of weight, temperature andpressure.Holdings, Inc.)