Comment Details
| Comment Author: | Llewellyn Matthews |
| Organization: | Northwest Pulp and Paper Association |
| Comment Date: | Tuesday, 19 May 2009 |
| Comments: |
Response to Stakeholder Comments and Final Draft Essential Requirements of Mandatory Reporting for the WCI: Northwest Pulp and Paper Association appreciates WCI acknowledgment of the proposed EPA mandatory reporting rule, released on March 10, 2009. WCI notes that "the U.S. EPA rule is designed to inform a number of policies whereas WCI reporting requirements must be sufficiently accurate to support cap and trade. WCI has not had sufficient time after the release of the proposed U.S. EPA rule to incorporate consideration of that proposed rule into the current document, but the U.S. EPA rule will be considered as WCI develops the Final Essential Requirements, to be released in June." Comment: NWPPA respectfully suggests that WCI is moving too quickly to fully consider the proposed U.S. EPA rule within the timeframe stated. Comments are due on the WCI proposal on June 4th and comments are due on the U.S. EPA proposal on June 9th. WCI is apparently expecting to finalize its essential requirements during the month of June, prior to U.S. EPA's response and modifications based on the comments it receives. The result will inevitably lead to conflicts in requirements and increases the possibility of duplicative reporting. Furthermore, many within the affected industries will be hard pressed to complete comments responsive to both deadlines. Pulp and paper is both a complex industry and a carbon intensive industry with its own set of reporting tools that are now part of the WRI/WBSCD GHG Protocols. Due to the complexity of our industry and the work we have already completed that must evaluated in light of both the U.S. EPA and WCI proposals, our industry has concerns both meeting the very short time frames and responding to two moving targets. For this reason, NWPPA respectfully requests that WCI extend the comment deadline for its proposal. Thank you in advance for your consideration. Sincerely, Llewellyn Matthews, Executive Director, NWPPA 1300 114th Ave SE Suite 200 Bellevue, WA 98040 |