S I A I 

SEMICONDUCTOR 

IlIIoUSTRY 

ASSOCIATlolII 

BY HAND DELIVERY 

February 25,2010 

Kirsten Cappel 

Deborah Ottinger 

U.S. Environmental Protection Agency 

1310 L Street, N.W. 

Washington, D.C. 20005 

Re: GHG Reporting Rulemaking 

Dear Ms. Cappel and Ms. Ottinger: 

SIA appreciates the opportunity to work with you and others at EPA in connection with 

the GHG reporting rulemaking as well as the EPA's decision to defer promulgation of a final 

rule for semiconductor manufacturing operations. We look forward to participating in the 

additional rulemaking that we understand will get underway in the near future. 

In the period since EPA made its decision to defer, SIA member companies have shared 

general information and, in some cases, data regarding current manufacturing operations. Some 

members also responded to an EPA "survey" seeking detailed labor burden projections in 

connection with estimating PFC emissions. EPA sought estimated labor hours by type (legal, 

managerial, technical, and clerical) along with other capital and annual operating costs. This 

survey requested these projections be broken down separately into the following categories: 

measuring DRE of point-of-use abatement devices; estimating facility/gas specific heel factors; 

estimating gas usage by process type based on engineering estimates; and developing emission 

factors by process type. For the data by process type, EPA requested that companies use anew, 

expanded "process definition" developed by EPA and provided to the companies for the first 

time through this survey. 

SIA is concerned about the introduction of this new "processes" definition developed by 

EPA. The definition itself does not necessarily reflect the realities across all semiconductor 

facilities. The specificity of the process categories is unrelated to the significance of GHG 

emissions from those categories. Most importantly, the definition, if used as the framework for 

GHG emissions reporting, would not measurably reduce the reporting burden from the proposed 

rule in the event EPA were to require IPCC Tier 3 measurements for all of the equipment sets 

covered by the definition. Even if default emission factors were used, the large number of 

categories would require expenditures for gas consumption measurement that would be 

comparable to those for the rule as originally proposed. 

SIA continues to believe that EPA can obtain GHG emissions data of sufficient accuracy 

and reliability using the approach detailed in our comments on the proposed rule: 
Kirsten Cappel & Deborah Ottinger 

February 25, 2010 

Page 2 of 2 

-/ Require use of Tier 3 measurement data where in possession of the facility, and 

otherwise to allow use of the Tier 2b method, with a reasonable period for the facility to 

transition to that method to the extent it has been relying on Tier 2a or other methods in 

connection with the PFC Reduction Partnership or other federal and state programs. 

-/ Mandate gas-specific heel factors specific to each type of cylinder and for each gas type 

based on the point established as the trigger for changing out the cylinder, unless 

infeasible. For bulk systems or large cylinders of low usage gas, using scales to measure 

gas consumption from these systems should be retained as an option. 

-/ Allow mass balance keyed to purchase and offsite shipment for heat transfer fluids. 

-/ Allow default factors for abatement devices designed for F-GHG reduction. 

If EPA were to adopt the above approach, it would not preclude further efforts to refine 

measurement methodologies. Indeed, SIA would consider supporting the development in the 

future of more process-specific emission factors through a collaborative effort, such as the next 

IPCC evaluation, by working with our tool suppliers to gather more data and to share the cost of 

testing. This approach would provide the best path forward: not only would it promote the 

international collaboration and acceptance that is necessary to avoid serious damage to 

competitiveness of U.S.-based semiconductor operations, but it also would ensure greater 

transparency and burden sharing. 

We look forward to discussing this possibility with you and to our continued cooperation 

with the Agency in connection with the GHG reporting rulemaking. 

Thomas P. Diamond, crn 

Environmental, Health and Safety Director 

cc: Laura Mendicino, Chair of SIA Climate Change Working Group 

DC\127968S.3