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MEMORANDUM

DATE: September 2014

TO: Docket EPA-HQ-OAR-2010-0929

FROM: Lisa Grogan-McCulloch, U.S. EPA

SUBJECT: Assessment of Cost Impacts of 2015 Inputs Final Rule – Revisions to Reporting, 

Recordkeeping, and Verification Requirements under the Greenhouse Gas 

Reporting Program

1.0 INTRODUCTION 

Facilities subject to the GHG reporting rule (40 CFR part 98, hereafter referred to as “Part 98”) 

must report their GHG emissions to the EPA through the electronic Greenhouse Gas Reporting 

Tool (e-GGRT). The EPA is revising the reporting and recordkeeping requirements in Part 98 

that apply to reporters subject to any of the 23 subparts listed in Table 1. The revisions include:

 Adding a requirement for certain reporters under 23 subparts to use an EPA-provided 

inputs verification tool. For these subparts, the designated inputs to emission equations 

for which reporting was deferred to 2015 (hereafter referred to as “input to equations’ 

data elements”) and disclosure concerns have been identified are entered into the tool.a

The tool calculates the emission equation results and performs electronic verification. 

The tool does not retain the entered inputs (i.e., the inputs would not be reported to the 

EPA); instead, the tool conducts certain checks (e.g., accuracy of the inputs) at the time 

of data entry and generates a verification summary. The verification summary, which is

accessible to the EPA once the annual report is submitted, provides the EPA with 

information to conduct further verification if necessary.

 For reporters required to use the inputs verification tool, changing the required format for 

maintaining records of these inputs to emission equations.

 For reporters required to use the inputs verification tool, lengthening the record retention 

period from 3 to 5 years for all records maintained under Part 98 (including subparts that 

do not require the use of the tool).

 

a The inputs verification tool is not required to be used by reporters for any reported GHG for which the reporter uses a CEMS or 

an EPA-approved alternative method (as allowed under sections 98.33(a)(5), 98.53(a)(2), and 98.223(a)(2) of Part 98) to 

calculate the reported GHG value, rather than using "inputs to equations" data elements and the associated EPA-provided 

calculation methodologies to calculate the reported GHG value.
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 For certain reporters required to use the inputs verification tool, adding new data 

elements to be reported for the EPA’s verification purposes. The EPA is also finalizing

confidentiality determinations for the new data elements to be reported.

 For reporters required to use the inputs verification tool, removing the requirement to 

report the inputs to emission equations for which reporting was deferred to 2015 and 

disclosure concerns have been identified, and requiring these data to be kept as records.

 For subpart W, delaying reporting of six inputs to equations related to specific types of 

exploratory wells for two years to prevent early public disclosure of potentially sensitive 

information. The EPA determined there was no burden associated with this decision.

Table 1. Subparts Affected by the Revisions to Reporting, Recordkeeping, and Verification 

Requirements

Subpart Source Category

Number of “Inputs to Equations” Data Elements

Currently Required to 

be Reported

For which Reporting 

is to be Removed

C General Stationary Fuel Combustion 

Sources except Certain Electric GeneratorsI 26

II 26II

E Adipic Acid Production 21 11

F Aluminum Production 29 29

G Ammonia Manufacturing 8 8

H Cement Production 16 14

K Ferroalloy Production 13 13

N Glass Production 3 3

O HCFC-22 Production and HFC-23 

Destruction 15 12

P Hydrogen Production 7 7

Q Iron and Steel Production 86 85

R Lead Production 10 10

S Lime Manufacturing (non-CEMS) 9 9

U Miscellaneous Uses of Carbonate 6 6

V Nitric Acid Production 21 21

X Petrochemical Production 19 19

Y Petroleum Refineries 75 70

Z Phosphoric Acid Production 4 4

AA Pulp and Paper Manufacturing 31 28

BB Silicon Carbide Production 3 3

CC Soda Ash Manufacturing 10 4

EE Titanium Dioxide Production 2 2

GG Zinc Production 8 8

TT Industrial Waste Landfills 4 3
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Table 1. Subparts Affected by the Revisions to Reporting, Recordkeeping, and Verification 

Requirements

Subpart Source Category

Number of “Inputs to Equations” Data Elements

Currently Required to 

be Reported

For which Reporting 

is to be Removed

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For subpart C, stationary fuel combustion sources (e.g., individual units, aggregations of units, common pipes, or common 

stacks) are not affected by the final amendments if they contain at least one combustion unit connected to a fuel-fired electric 

generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility 

commission (PUC) (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D) and that are 

located at a facility for which the sum of the nameplate capacities for all such electric generators is greater than or equal to 1 

megawatt electric output. All other subpart C sources may elect to report inputs to emission equations rather than use the 

inputs verification tool. If these sources elect to report inputs to equations, they are not affected by the final amendments.

II Includes one deferred “inputs to equations” data element, 40 CFR 98.3(d)(3)(v), which is specified in subpart A of Part 98 

and applies to only certain reporters under subpart C of part 98.

This memorandum documents the EPA’s assessment of the cost impacts associated with the 

revisions to the GHGRP. Section 2.0 of this memorandum contains a description of the analyses 

conducted to estimate cost impacts. Section 3.0 presents the results of the analyses. 

2.0 DESCRIPTION OF ANALYSIS CONDUCTED 

Under this analysis, the EPA estimated the cost of the changes to the GHGRP as the incremental 

costs above the previously estimated costs of the program as promulgated in 2009 (refer to the 

2009 Impacts Analysis)1. The EPA calculated this incremental cost based on the number of 

reporters that submitted a GHG report in 2012 under each subpart specified in Table 1. To 

calculate the incremental cost, the EPA estimated the following for each subpart: (1) the cost for

each facility to become familiar with the inputs verification tool within e-GGRT, and (2) the 

costs associated with reporting the new data elements. To estimate the number of reporters 

affected by the new data elements, the EPA used the number of reporters that submitted a GHG 

report in 2012 under each of the 9 subparts for which the new data elements would be reported. 

To estimate hourly wages, the EPA used the labor costs per hour for technical, managerial, and 

legal hours specified in the Bureau of Labor Statistics Index for 2011, consistent with the most 

current information collection request for the GHGRP. These costs are presented in Table 2. 

Table 2. Labor Costs - Year 2011

Labor 

Category Description Hourly Rate ($/hour)

Legal

Oversees legal aspects of company reports and data-reporting 

forms. 109.94

Managerial

Oversees work at a high level and is the final authority on all 

reporting requirements. 77.23
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Technical

Conducts monitoring of emissions sources, checks for accuracy, 

performs measurements. 59.12

Clerical Assists with documentation and recording information 31.35

2.1 Use of the Electronic Inputs Verification Tool

The EPA is eliminating the reporting of many “inputs to equations” data elements, due to 

disclosure concerns. The EPA is replacing these reporting requirements with a requirement to 

enter the data into a new inputs verification tool within e-GGRT. For more information on the 

inputs verification tool, refer to the memorandum documenting the EPA’s analysis of alternative 

verification approaches in docket EPA-HQ-OAR-2010-0929.

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The EPA has determined that there will be no cost increase to enter “inputs to equations” data 

elements into the inputs verification tool, as compared to the cost associated with reporting these

data via e-GGRT (i.e., the EPA’s previous cost estimate under the original 2009 rule for

reporting these data )1. The EPA expects that reporters would spend the same time to complete

entry of “inputs to equations” data elements into the inputs verification tool as they would spend 

reporting these data via e-GGRT. The EPA recognizes, however, that there may be some time 

associated with learning the new procedures for the verification tool. The EPA has estimated that 

each reporter will spend one technical hour to become familiar with the inputs verification tool. 

Based on this technical labor estimate, the associated clerical and managerial labor hoursb, and 

an estimated 5,795 affected reporters (the number of reporters in 2012 under one or more of the 

affected subparts in Table 1), the EPA estimates that using the new inputs verification tool would

cost approximately $383,000 for the first year. 

2.2 New Data Elements

In order to facilitate the verification of data and ensure that the EPA has the information needed 

to better understand emissions associated with reporters, the EPA is requiring that reporters 

under 9 subparts report a total of 21 new data elements (that were not previously required to be 

reported) with their annual report. Table 3 summarizes the new data elements for each subpart 

and presents an analysis of the data availability for each data element. For the 21 data elements 

added to the 9 subparts listed in Table 3, the EPA has estimated that 14 of these are values that 

could be calculated using data currently required to be reported. For example, under subpart H, 

the EPA is proposing to replace the current reporting requirement to report the monthly kilnspecific clinker CO2 emission factor for each kiln with a requirement to report the annual 

average clinker CO2 emission factor for the facility, averaged across all kilns. For the purposes 

 

b Clerical and managerial and hours are assumed to be 10 percent and 5 percent, respectively, of technical labor 

hours.
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of reporting the new data element, a reporter under subpart H would calculate an annual average 

facility-wide value based on the current monthly values for all kilns. As a result, there will be no 

additional monitoring cost associated with these data elements. For these 14 data elements for 

which the underlying data (used to calculate the data element) are currently being reported, and 

only a simple change to a calculation spreadsheet would be required to fulfill the reporting 

requirement, the EPA has estimated a nominal additional cost to report the data element of 0.5 

technical hours per data element for reporting requirements.

The remaining 7 new data elements that will be reported are available from current facility

procedures used for accounting purposes or design and purchase documents. These data elements 

are related to annual production or raw material use, and are collected by reporters as a routine 

part of conducting business. The EPA is not requiring additional monitoring requirements for 

these data elements, but would allow the use of data collected for normal business purposes. 

Therefore, there will be no additional monitoring cost associated with these data elements. 

Table 3. New Data Elements for Part 98

Subpart New Data Element Analysis of Data Availability

E - Adipic Acid If only cyclohexane is oxidized to produce 

adipic acid: the annual quantity of 

cyclohexane (tons) used to produce adipic 

acid. If materials other than cyclohexane are 

oxidized to produce adipic acid: the annual 

quantity of cyclohexanone and cyclohexanol 

mixture (metric tons) used to produce adipic 

acid.

Available from plant procedures 

used for accounting purposes. 

Raw material consumption is 

necessary for financial accounting 

purposes. 

Annual percent nitrous oxide (N2O) emission 

reduction for all production units combined.

Calculated value using available 

data for percent emission reduction 

data from each unit. No additional

measurement required.

G - Ammonia Annual ammonia production (metric tons, 

sum of all process units reported within 

subpart G).

Available from plant procedures 

used for accounting purposes. 

Quantity of product produced is 

necessary for financial accounting 

purposes. 

Annual methanol production (metric tons) 

for each process unit.

Available from plant procedures 

used for accounting purposes. 

Quantity of product produced is 

necessary for financial accounting 

purposes.

H - Cement Annual clinker production (metric tons). Calculated value using available 

data for monthly clinker 

production currently required for 

emissions equations. No additional 

measurement required.
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Table 3. New Data Elements for Part 98

Subpart New Data Element Analysis of Data Availability

Annual average clinker CO2 emission factor 

for the facility, averaged across all kilns 

(metric tons CO2/metric ton clinker 

produced).

Calculated value using available 

data for clinker emission factor for 

each kiln and total clinker 

production. No additional 

measurement required.

Annual average cement kiln dust (CKD) CO2

emission factor for the facility, averaged 

across all kilns (metric tons CO2/metric ton 

CKD produced).

Calculated value using available 

data for CKD from each kiln. No 

additional measurement required.

P - Hydrogen Name and annual quantity (metric tons) of 

each carbon-containing fuel and feedstock.

Available from plant procedures 

used for accounting purposes. 

Raw material consumption and 

fuel consumption are necessary for 

financial accounting purposes. 

Annual methanol production (metric 

tons) for each process unit.

Available from plant procedures

used for accounting purposes. 

Quantity of product produced is 

necessary for financial accounting 

purposes.

Q - Iron & Steel If you use the carbon mass balance method 

in 40 CFR §98.173(b)(1) to determine CO2 

emissions: The annual mass (metric tons) of 

all gaseous, liquid, and solid fuels 

(combined) used in process units specified in 

Equations Q-1 through Q-7, calculated as 

specified in Equation Q-9 in the final rule 

amendments. Do not include fuel used in a 

stationary combustion unit where emissions 

are reported under subpart C.

Calculated value using available 

data for mass of each fuel. No 

additional measurement required.

If you use the carbon mass balance method 

in 40 CFR §98.173(b)(1) to determine CO2 

emissions: The annual mass (metric tons) of 

all non-fuel material inputs (combined) 

specified in Equations Q-1 through Q-7 of 

subpart Q, calculated as specified in 

Equation Q-10 of subpart Q .

Calculated value using available 

data for each non-fuel input. No 

additional measurement required.

If you use the carbon mass balance method 

in 40 CFR 98.173(b)(1) to determine CO2 

emissions: The annual mass (metric tons) of 

all solid and liquid products and byproducts 

(combined) specified in Equations Q-1 

through Q-7 of subpart Q, calculated as 

specified in Equation Q-11 of subpart Q.

Calculated value using available 

data for each product and 

byproduct. No additional 

measurement required.

If you use the carbon mass balance method 

in 40 CFR 98.173(b)(1) to determine CO2 

Calculated value using available 

data of carbon content for each 
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Table 3. New Data Elements for Part 98

Subpart New Data Element Analysis of Data Availability

emissions: The weighted average carbon 

content of all gaseous, liquid, and solid fuels 

(combined) included in Equation Q-9 of 

subpart Q being finalized in today’s action, 

calculated as specified in Equation Q-12 of 

subpart Q.

fuel. No additional measurement 

required.

If you use the carbon mass balance method 

in 40 CFR 98.173(b)(1) to determine CO2 

emissions: The weighted average carbon 

content of all non-fuel inputs to all furnaces 

(combined) included in Equation Q-10 of 

subpart Q being finalized in today’s action, 

calculated as specified in Equation Q-13 of 

subpart Q.

Calculated value using available 

data of carbon content for each 

non-fuel input to each furnace. No 

additional measurement required.

If you use the carbon mass balance method 

in 40 CFR 98.173(b)(1) to determine CO2 

emissions: The weighted average carbon 

content of all solid and liquid products and 

byproducts from all furnaces (combined) 

included in Equation Q-11 of subpart Q 

being finalized in today’s action, calculated 

as specified in Equation Q-14 of subpart Q.

Calculated value using available 

data of carbon content for each 

product and byproduct. No 

additional measurement required.

S - Lime Annual quantity (tons) of lime product sold, 

by type.

Available from plant procedures 

used for accounting purposes. 

Quantity of product produced is 

necessary for financial accounting 

purposes.

V - Nitric Acid Annual percent N2O emission reduction for 

all nitric acid trains combined.

Calculated value using available 

data of emission reduction for each 

production unit. No additional 

measurement required.

X - Petrochemicals If using the CEMS method to calculate GHG 

emissions: Name and annual quantity (in 

metric tons) of each product. If using the 

mass balance method to calculate GHG 

emissions: Name and annual quantity (in 

metric tons) of each product used in 

Equations X-1, X-2, and X-3 of subpart X.

Calculated value using available 

data of monthly quantities of 

feedstocks. No additional 

measurement required. 

If using the CEMS method to calculate GHG 

emissions: Name and annual quantity (in 

metric tons) of each carbon-containing 

feedstock. If using the mass balance method 

to calculate GHG emissions: Name and 

annual quantity (in metric tons) of each 

carbon-containing feedstock used in 

Equations X-1, X-2, and X-3 of subpart X.

Calculated value using available 

data of monthly quantities of 

products. No additional 

measurement required.
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Table 3. New Data Elements for Part 98

Subpart New Data Element Analysis of Data Availability

AA - Pulp & Paper For each pulp mill lime kiln: Quantity of 

calcium oxide (CaO) produced (metric tons).

Available from plant procedures 

used for accounting purposes. 

Quantity of product produced is 

necessary for financial accounting 

purposes.

For each pulp mill lime kiln: Percentage of 

annual heat input, individually for each fossil 

fuel type.

Calculated using known quantities 

of fuel and heat value of fuel. No 

additional measurement required.

For these data elements, the EPA has estimated that there is little cost to the reporter to acquire 

the data and report the values during the reporting process. However, we have also assigned a 

cost of 0.5 technical hours per data element to provide a conservative estimate of costs.

For all 21 new data elements, the EPA estimated that legal and managerial hours would be 5 

percent and 10 percent, respectively, of the technical hours. The EPA estimated the number of 

reporters based on the annual reports received in 2012 for the 9 subparts.

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Table 4 shows the 

number of affected reporters by subpart and the number of data elements to be reported for each 

subpart. Based on these data, the total estimated costs associated with reporting for the 21 data 

elements in the 9 subparts listed in Table 4 is $55,000. 

Table 4. Subparts with New Data Elements Reported

Subpart Source Category

Number of New Data 

Elements Number of Reporters

E Adipic Acid Production 2 3

G Ammonia Manufacturing 2 22

H Cement Production 3 82

P Hydrogen Production 2 74

Q Iron and Steel Production 6 126

S Lime Manufacturing (non-CEMS) 1 75

V Nitric Acid Production 1 35

X Petrochemical Production 2 64

AA Pulp and Paper Manufacturing 2 111

2.3 Recordkeeping changes

The changes to the GHGRP include a provision to retain records of all “inputs to equations” data 

elements for five years instead of the three years currently required. Additionally, the EPA is 

requiring reporters who use the inputs verification tool to maintain a record of a file generated by 

the tool, which lists the entered “inputs to equations” data elements. This list of data elements 

could be maintained in a format (e.g., electronic, hard copy) currently allowed under Part 98. The 
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EPA does not anticipate that this change to the recordkeeping requirements would create any 

additional burden for a reporting facility in addition to the recordkeeping burden estimated in the 

2009 Impact Analysis.

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3.0 RESULTS OF ANALYSIS

The total cost of the proposed changes is presented in Table 5. The EPA estimates that the first 

year net cost would be $438,000, which includes the one-time cost of learning the verification 

system. The EPA estimates recurring costs to be $55,000 for reporting of new data elements. 

Details of the recordkeeping and reporting burden estimate analysis can be found in the ICR 

supporting statement for the 2015 inputs final rule in the docket (Docket ID No. EPA-HQ-OAR2010-0929).

Table 5. Summary of Changes to Costs of GHGRP for 2015 Inputs Rule

Cost Element First Year Costs Subsequent Year Costs 

Verification tool (training) $383,000 N/A

Reporting for New Data Elements $ 55,000 $55,000

Net Cost $438,000 $55,000

4.0 REFERENCES

1. Regulatory Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions 

Final Rule (GHG Reporting). U.S. Environmental Protection Agency. September 2009.

http://www.epa.gov/ghgreporting/documents/pdf/archived/EPA-HQ-OAR-2008-0508-2229.pdf

2. Evaluation of Alternative Verification Approaches for Greenhouse Gas Reporting Rule 

Subparts for which Reporting of Inputs to Emission Equations was Deferred to March 31, 

2015. Memorandum from Lisa Grogan-McCulloch, U.S. EPA to Docket EPA-HQ-OAR2010-0929. August 2013.

3. 2012 Greenhouse Gas Emissions from Large Facilities. 

http://ghgdata.epa.gov/ghgp/main.do