An environmental figure can inform the public and still mislead if its meaning is lost. EPA's reporting amendments, published December 9, 2016 and considered here in a December 11 weekend retrospective, extend relevant supplier reporting to fluorinated heat-transfer fluids that are not also fluorinated greenhouse gases, starting with reporting year 2018. [2016-28564][2015-32753]

The added information concerns emissions that would result from releasing fluids covered reporters produce, import, export, transform or destroy. It does not establish that those releases happened. Fair communication owes affected communities that distinction, just as it owes businesses an accurate account of who is covered. The supplier provision does not automatically encompass every user of the fluids. [2016-28564][2015-32753]

There is another balance in the record. EPA's January 15 proposal sought changes to reporting and confidentiality treatment, while anticipating both added burdens and savings from simplification. The final action adopts confidentiality determinations for certain data elements. More reporting therefore should not be described as a promise that all business information becomes public. Transparency and appropriate confidentiality remain separate questions. [2016-28564][2015-32753]

Different final instructions take effect on January 1 in 2017, 2018 and 2019. This staged implementation supports a patient, specific account of what institutions undertake, rather than a declaration that environmental stewardship has already succeeded. The proposal and final action are one evidence chain. They document agency choices and objectives, not independently measured reductions in emissions or a settled judgment about the fairness of every reporting burden. [2016-28564][2015-32753]

Source documents

  1. 2015 Revisions and Confidentiality Determinations for Data Elements Under the Greenhouse Gas Reporting Rulehttps://www.govinfo.gov/content/pkg/FR-2016-12-09/html/2016-28564.htm
  2. 2015 Revisions and Confidentiality Determinations for Data Elements Under the Greenhouse Gas Reporting Rulehttps://www.govinfo.gov/content/pkg/FR-2016-01-15/html/2015-32753.htm