Submitted Comment Name Lindsay Scherr Affiliation N/A Subject Disclosure by scope and GHG Message To ease reporting for national and international companies, we propose that emissions be reported by scope and greenhouse gas (GHG). Large companies such as ours and many of our peers, are facing a heavy regulatory and voluntary reporting loads which includes reporting in alignment with various global warming potentials. The current program proposes reporting under AR4, but we are currently required to meet the EPA GHG Reporting Program standard aligned with AR5. Additionally, we are encouraged to report under AR6 in voluntary reporting scenarios to maintain alignment with the latest climate science. The variety of guidance frameworks places additional strain on already overburdened reporting teams. It also creates confusion for data users, who often lack the time or understanding to differentiate between these methodologies. While the discrepancies among global warming potentials (GWPs) may be immaterial for many industries, they are highly consequential for a waste company, where methane is the most potent greenhouse gas. In such cases, the choice of GWP can result in more than a 10% variation in total reported emissions. Allowing companies to report their emissions by GHG will eliminate the added burden put on reporting teams to account for their emissions in multiple ways while also significantly reducing the potential misalignment of data that currently exists among regulatory standards. File Upload (i.e., Attachments): N/A N/A
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