Mar. 30, 2022
Dear Commissioner Gensler, Please ensure that the new rule has enough detail at a micro level to verify disclosures. For example, every facility has a specific FRS ID number in the EPA ECHO database. Disclosures should be tied to a geographical location before they are added up for each company so that we can verify. For example, the Exxon refinery in Baton Rouge has a FRS ID number of 110043804185 as shown on the ECHO database on page https://echo.epa.gov/detailed-facility-report?fid=110043804185. This level of detail is necessary because of the complexity of the ownerships of each limited liability corporation that was set up to shield the liability of the parent company. For example, PBF Energy is constructing a new refinery for renewable diesel in New Orleans and uses a separate company to transport the fuel to California, all to meet the renewable fuel requirement for PBF Energy. This added cost of transport was cheaper than refining the renewable diesel at their California plant because Cali fornia requires expensive pollution control technology that Louisiana doesnt. Louisiana has the weakest standards and enforcement in the nation. We need the disclosures to illuminate all the GHG that are being generated in refining and transportation just because one state has weak laws. The fracking industry generates huge piles of waste petroleum coke. This waste product is being sold for cheap to other companies as a cheap source of fuel but it is the worst kind of fuel, emitting the highest levels of sulfur dioxide. The emissions from the waste petroleum coke should show up on the disclosures of the fracking industry, just like nuclear waste shows up on the balance sheets of power companies that general nuclear power. The true cost of fracking needs to be disclosed in a market economy so that companies are not allowed to swim profits while externalizing environmental costs. Please detail how LNG exporters will be required to disclose. For example IPPC rules require that LNG generated on US soil be on our balance sheet even though the product may have been exported to Asia. We are witnessing a huge gold rush for LNG export terminals here in Louisiana and all forecasts are for even higher exports. Please also detail how disclosures will be verified for the thousands of air emission permits in Louisiana that were not required to install basic continuous monitoring equipment. Thank you, Tom Adler end