Summary of Comments Received on the Draft Version of EPA S Shipyard GHG Inventory Tool

Summary of comments received on the draft version of EPA’s Shipyard GHG Inventory Tool:

Cash-Robertson, William (9/3/08)

Northrop Grumman Corporation

The title on the top right chart on the summary page was corrected to read “…Stationary Combustion…”

ICF: Comment Implemented

The workbook caption was corrected to show the correct version 2.0

ICF: Shipyard Tool now version 2.1

“Rev NGNN” was added to the workbook caption to denote that this version has been tweaked by us. (“Rev NGNN” can be removed later by editing one of the macros.)

ICF: Newport News specific, no action necessary

A new chart was added to the summary page (Percent of Total Emissions, by Source, at bottom right) showing the contribution of each category/scope to the bottom line. This shows quickly which categories are the major and minor contributors to total GHG emissions.

ICF: Comment Implemented

The Scope 1 subtotals on the summary page were repositioned to beneath the rows of source types instead of at the top, to permit a quicker understanding of the summary data.

ICF: Comment Implemented

Sara A. Giobbi (8/18/08)

General Dynamics NASSCO

Just an observation - I noticed that the calculation for the indirect emissions from electricity usage are done using the E-Grid factors for STATE emissions whereas other tools we have tested used the E-Grid factors for SUBREGION emissions. As a result, their tool uses a factor of 700 lb/MWhr whereas other tools (including the Ca Climate Registry's CARROT protocol) use 879 lb/MWhr. I am not enough of an expert to know if either of these approaches is more "correct", but I have noticed a difference.

ICF ACTION: The “appropriate” emission factor for purchased electricity can vary depending on the registry, program, or other purpose the tool is being used for. Therefore, the purchased electricity section allows the user to override the provided emission factor (E-Grid state level) with their preferred factor.

Shaun Halvax (9/15/08)

US SSA

I would note that the stationary source note identifying portable generators might identify equipment like Portable air compressors and fire pumps for clarity. Air compressors are a large fuel consumer in many shipyards.

ICF ACTION: Comment Implemented