SUPPORTING STATEMENT PART A:

INFORMATION COLLECTION REQUEST

FOR THE

GREENHOUSE GAS REPORTING PROGRAM

OMB Control No. 2060-0629

EPA ICR No. 2300.10

DRAFT

May 2012
ICR for the GHGRP, DRAFT Page 1 May 2012

SUPPORTING STATEMENT

FOR THE GREENHOUSE GAS REPORTING PROGRAM 

EPA ICR # 2300.10

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection

TITLE: “Information Collection Request for the Greenhouse Gas Reporting Program

(GHGRP).”

ICR Number: 2300.10

OMB Control Number: 2060-0629

1(b) Short Characterization/Abstract

In response to the FY2008 Consolidated Appropriations Act (H.R. 2764; Public Law 

110-161) and under authority of the Clean Air Act (CAA), EPA finalized a greenhouse gas 

reporting rule in October of 2009 (henceforth referred to as the Greenhouse Gas Reporting 

Program or GHGRP) (74 FR 56260; October 30, 2009). The Rule, which became effective on 

December 29, 2009, requires reporting of greenhouse gases (GHGs) from certain facilities and 

suppliers. It does not require control of greenhouse gases. Instead, it requires that sources 

emitting above certain threshold levels of carbon dioxide (CO2) equivalent (CO2e) monitor and 

report emissions.

Subsequent rules provide corrections and clarification on existing requirements (e.g., 

modify reporting deadlines, amend calculation methodologies and data reporting requirements, 

clarify rule provisions and compliance obligations, and correct technical and editorial errors); 

include requirements for additional facilities suppliers, and mobile sources; require reporters to 

provide information about parent companies, North American Industry Classification System 

(NAICS) code(s), and whether emissions are from cogeneration; and finalize confidentiality

determinations. 

The Office of Management and Budget’s (OMB’s) approval of the Information 

Collection Request (ICR) for the GHG Reporting Rule expires on November 30, 2012. The 

purpose for this ICR is to renew and revise the GHG Reporting Rule ICR to update and combine 

the burdens and costs imposed by all of the current ICRs under the GHGRP. Appendix A

summarizes the ICRs associated with the GHGRP. 

There is a decrease of 764,890 hours and $43,137,000 in the total estimated respondent 

burden compared with that identified in the ICRs associated with the GHGRP currently approved 

by OMB. This decrease reflects the completion of one-time activities that occurred in the first 

year of data collection and a reduction in the number of respondents. This change is the result of 

a program adjustment.
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2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

Signed into law on December 26, 2007, the FY2008 Consolidated Appropriations Act

(henceforth referred to as the “Appropriations Act”) directed EPA to “develop and publish a 

draft rule not later than 9 months after the date of enactment of this Act, and a final rule not later 

than 18 months after the date of enactment of this Act, to require mandatory reporting of 

greenhouse gas emissions above appropriate thresholds in all sectors of the economy of the 

United States.” 

The accompanying explanatory statement further directed EPA to “use its existing 

authority under the Clean Air Act” (CAA) to develop a GHG reporting rule. “The Agency is 

further directed to include in its rule reporting of emissions resulting from upstream production 

and downstream sources, to the extent that the Administrator deems it appropriate. The 

Administrator shall determine appropriate thresholds of emissions above which reporting is 

required, and how frequently reports shall be submitted to EPA. The Administrator shall have 

discretion to use existing reporting requirements for electric generating units under Section 821”

of the 1990 CAA amendments.

In accordance with this directive, EPA has developed the GHGRP using its authority

under Section 114 of the CAA. CAA Section 114(a) provides EPA broad authority to collect data 

for the purpose of, among other things, “carrying out any provision” of the Act. Under Section 

114(a)(1), EPA may require any person who owns or operates any emission source or may have 

information necessary to carry out the provisions of the Act to measure emissions (including 

installing monitoring equipment), maintain records, submit reports, and provide other 

information the Administrator may reasonably require. 

The CAA also provides EPA with authority in other provisions. CAA Section 208, in 

Title II of the Act, provides EPA with authority regarding the manufacturers of new motor 

vehicles or new motor vehicle engines. EPA may gather information for purposes of establishing 

implementation plans (under CAA Section 110) or emissions standards (under CAA Section 

111). In addition, CAA Section 103 authorizes EPA to establish a national research and 

development program, including non-regulatory approaches and technologies for the prevention 

and control of air pollution as it relates to GHGs and climate change. 

Because EPA does not yet know the specific policies that will be adopted, the data 

reported under the GHGRP is of sufficient quality to inform policy and program development. 

The requirements in the GHGRP maximize the amount of emissions reported while excluding 

small emitters and are consistent with existing GHG reporting programs in order to reduce 

reporting burden for all parties involved. Also, consistent with the Appropriations Act, the 

GHGRP covers a broad range of sectors of the economy. 
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2(b) Practical Utility/Users of the Data

The GHGRP collects information from facilities that directly emit GHGs and from 

suppliers of products that release GHGs if combusted, oxidized, or used. The comprehensive 

GHG data reported directly from large facilities and suppliers across the country are now easily 

accessible to the public at: http://ghgdata.epa.gov/ghgp/main.do. Reporting entities use uniform 

methods for estimating emissions, which enables data to be compared and analyzed. EPA’s 

online data publication tool allows users to view and sort GHG data for calendar year 2010 from 

over 6,000 entities in a variety of ways, including by location, industrial sector, and the type of 

GHG emitted. 

Transparent, public data on emissions allows for accountability of polluters to the public 

stakeholders who bear the cost of the pollution. This powerful data resource provides a critical 

tool for communities to identify nearby sources of GHGs and provide information to state and 

local governments.

The standardization of GHG data provides businesses with the necessary information to 

benchmark themselves against similar facilities, better understand their relative standing within 

their industry, and achieve and disseminate their environmental achievements. Businesses and 

other innovators can use the data to determine their GHG footprints, find cost- and fuel-saving 

efficiencies that reduce greenhouse gas emissions (e.g., through energy audits or other forms of 

assistance), and foster technologies to protect public health and the environment.

The facility-specific GHG emissions data improve the understanding of the factors that

influence GHG emission rates as well as the actions that facilities take to reduce emissions. The

facility-based data can be aggregated to the corporate level in order to track emission trends from 

industries, within industries, and across industries over time, particularly in response to policies 

and potential regulations. 

Information collected from the oil and gas facilities (in subpart W) and CO2 injection 

facilities (in subparts RR and UU) allows EPA to gain a better understanding of the entire CO2

capture and sequestration (CCS) system.

Information collected from fluorocarbons allows EPA to assess the overall volume and 

importance of compounds for which global warming potentials (GWPs) have not been evaluated 

and help identify which compounds should have their GWPs evaluated first. In addition, 

historical reports in tons of chemical can be converted into CO2e, provided GWPs have been 

identified for these compounds. Without this comprehensive reporting requirement, such 

historical information could be lost. 

The GHGRP is not intended to be a survey and the respondents affected by the program

are not intended to be a statistical sample of a larger universe of entities. EPA does not intend to 

use the data collected under the GHGRP to characterize non-reporting entities or to draw 

statistical inferences about a larger population.
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3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Nonduplication

EPA evaluated existing GHG programs and the GHG data currently available to 

determine whether this request duplicates other information collections. In developing the 

GHGRP, EPA reviewed monitoring methods including:

 Federal programs within the United States, such as the Inventory of U.S. Greenhouse 

Gas Emissions and Sinks (Inventory), the U.S. Department of Energy’s (DOE’s)

Energy Information Administration’s (EIA’s) 1605b program, the Acid Rain 

Program, EPA Natural Gas STAR Program, and voluntary GHG partnership 

programs;

 State and regional GHG reporting programs, such as The Climate Registry, the 

Regional Greenhouse Gas Initiative, the Western Regional Air Partnership, and 

programs in several states including California, New Mexico, Connecticut, and New 

Jersey;

 Reporting protocols developed by nongovernmental organizations, such as the World 

Resources Institute/World Business Council for Sustainable Development; and 

 Programs from industrial trade organizations, such as the Interstate Natural Gas 

Association of America’s GHG Emission Estimation Guidelines, the American 

Petroleum Institute’s Compendium of GHG Estimation Methodologies for the Oil and 

Gas Industry, and the World Business Council for Sustainable Development’s 

Cement Sustainability Initiative’s CO2 Accounting and Reporting Standard for the 

Cement Industry. 

These are important programs that not only led the way in reporting of GHG emissions 

before the federal government acted but also assisted in quantifying the GHG reductions 

achieved by various policies. Many of these programs collect different or additional data as 

compared to the GHGRP. For example, state programs may establish lower thresholds for 

reporting, request information on areas not addressed in the GHGRP, or include different data 

elements to support other programs (e.g., offsets). While some programs collect similar 

information on GHG emissions, the Agency has determined that the GHGRP supplements and 

complements, rather than duplicates, existing programs’ data. Further, EPA has made significant 

efforts over the past 4 years to facilitate the reporting in the event a single entity has to report 

both the federal and state level. For example, EPA has supported efforts by the California Air 

Resources Board to harmonize the reporting of information under Calinfornia’s Global Warming 

Solutions Act, AB32 with EPA’s GHGRP. The product of the collaboration is referred to as 

California Electronic Greenhouse Gas Reporting Tool, or Cal e-GGRT.

Documentation of EPA’s review of GHG monitoring protocols used by federal and state

voluntary and mandatory GHG programs as well as GHG reporting rules can be found in the 
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docket at EPA-HQ-OAR-2008-0508-056. For further discussion on the relationship of the 

GHGRP to other programs, please refer to the preambles of each of the GHGRP rulemakings, 

the June 6, 2008 memorandum entitled Review of Existing Programs (which can be found in the 

docket at EPA-HQ-OAR-2008-0508-0052), and the January 27, 2009 memorandum entitled 

Review of Existing State Greenhouse Gas Reporting Rules (which can be found in the docket at 

EPA-HQ-OAR-2008-0508-0054). Some GHG programs are described below:

 A number of EPA’s voluntary partnership programs include a GHG emissions and/or 

reductions reporting component (e.g., Natural Gas STAR program, etc.). However, 

the GHGRP has much broader coverage than the voluntary programs and therefore 

helps EPA learn more about emissions from facilities not included in current

programs.

 EPA considered CO2 data currently collected under Section 821 of the 1990 CAA 

Amendments. To avoid duplication and because the Acid Rain program already

requires reporting of high quality CO2 data from electrical generating units (EGUs), 

the GHGRP allows for use of the same CO2 data rather than requiring additional 

reporting of CO2 from EGUs. Facility operators do, however, have to report the 

emissions of GHGs that are not included under Section 821, such as methane (CH4) 

and nitrous oxide (N2O).

 EPA reviewed the Inventory of U.S. GHG Emissions and Sinks, which is an annual 

comprehensive top-down assessment of national greenhouses gas emissions. While 

the Inventory is generally compiled from national surveys (i.e., not broken down at 

the geographic or facility level), the GHGRP focuses on bottom-up data from 

individual facilities that exceed appropriate thresholds. The bottom-up approach to 

data collection in the GHGRP can help reduce uncertainty in emissions estimates for 

specific industries, and more broadly, helps EPA transition to use of the 2006 

Intergovernmental Panel on Climate Change (IPCC) Guidelines for National 

Greenhouse Gas Inventories, which will be required to meet international reporting 

obligations under the United Nations Framework Convention on Climate Change in 

the near future.

 EPA published the Federal Requirements Under the Underground Injection Control 

(UIC) Program for Carbon Dioxide Geologic Sequestration (GS) Wells Final Rule 

(henceforth referred to as the “GS Rule”) (75 FR 77230, December 10, 2010). EPA 

determined that the GHGRP is complementary to and builds on EPA’s UIC permit 

requirements. Requirements under the UIC program are focused on demonstrating 

that underground sources of drinking water are not endangered as a result of CO2

injection into the subsurface, while requirements under the GHGRP through subpart 

RR enable reporters to quantify the amount of CO2 that is geologically sequestered. 

For example, the UIC Class VI permit (including the Testing and Monitoring plan) 

and subpart RR’s monitoring, reporting, and verification plan have separate 

monitoring objectives.
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 EPA reviewed the Internal Revenue Service (IRS) Notice 2009-83 Credit for Carbon 

Dioxide Sequestration under Section 45Q. To claim the credit, a taxpayer must follow 

general monitoring and verification principles, calculate CO2 sequestered in the fiscal 

year using a mass-balance equation, and report to IRS the amount of qualified CO2

sequestered in the fiscal year. However, the level of reporting and transparency of the 

IRS data collected would not meet the verification needs of the GHGRP. The IRS 

reporting requirement expires after 75 million metric tons of CO2 is reported as 

sequestered to IRS, data reporting is only as robust as to meet the standards in the 

case of an IRS audit, and the IRS does not outline procedures for quantifying and 

reporting any CO2 leakage that may occur as is necessary for the rule. Therefore, EPA 

has concluded that the IRS data would not meet the needs outlined in the GHGRP.

As noted in the ICR for the 2009 GHG Reporting Rule, a number of programs at the 

state, tribal, territorial, and local level require emission sources in their respective jurisdictions to 

monitor and report GHG emissions. To reduce burden on reporters and program agencies, the 

Agency plans to share emissions data with the exception of any confidential business 

information (CBI) with relevant agencies or approved entities using, where practical, shared 

tools, and infrastructure.

3(b) Public Notice Required Prior to Information Collection Request (ICR)

Submissions to OMB

As part of the Federal Register notice on each of the rulemakings under the GHGRP, 

EPA solicited comments on the proposed rules, the estimates in the proposed ICRs, and specific 

aspects of the information collection, as described below:

1) Whether the proposed collection of information is necessary for the proper 

performance of the functions of the Agency, including whether the information would

have practical utility; 

2) Whether the Agency’s burden estimate is accurate, including the validity of the 

methodology and assumptions used;

3) How to enhance the quality, utility, and clarity of the information to be collected; and

4) How to minimize the burden on respondents, including use of appropriate automated 

electronic, mechanical, or other technological collection techniques or other forms of 

information technology.

Across all the ICRs associated with the GHGRP, EPA received only a couple of 

comments that specifically addressed the proposed ICRs, as follows.

EPA received one comment about the April 2010 proposed ICR for Subpart W. The 

commenter stated that use of CAA Section 114 as the basis for the rule runs counter to its 

longstanding use which has been limited to issuing ICRs and that ICRs are limited to collecting 

data from specific sources over a discrete period of time. EPA determined that this comment 

confuses CAA Section 114 and ICR requirements under the Paperwork Reduction Act, 44 

U.S.C. 3501, et seq.
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EPA received two written comments that questioned the need for EPA to collect parent 

company information under the Corporate ID Rule Amendment. One commenter submitted that 

company affiliation should not be used as a factor in policy development. The other commenter’s 

primary objection was that EPA had been vague and non-specific in justifying collection of 

parent company information, i.e., that EPA’s authority to collect information under Section 114 

is limited by the requirements of Paperwork Reduction Act (5 C.F.R. 1320) under which EPA 

must demonstrate that the requested information has “practical utility.” EPA explained that 

Section 114 of the CAA is sufficiently broad for EPA to collect this information.

In compliance with the Paperwork Reduction Act (44 USC 3501, et seq.), EPA solicited 

public comment on this GHGRP ICR for a 60-day period before it was submitted to OMB.

Specifically, EPA published a notice in the Federal Register (FR) requesting comment on the 

estimated respondent burden and other aspects of this ICR (XX FR XXXXX, see Appendix X).

An additional FR notice will be published prior to submission of this GHGRP ICR to 

OMB. The public comment period for this additional notice is 30 days.

3(c) Consultations

In developing the GHG Reporting Rule, EPA established several Agency workgroups, conducted 

a proactive communications outreach program, and met with federal agencies. EPA established 

several Agency workgroups to develop the reporting requirements for the GHG emitting 

processes within each of seven categories of processes that emit greenhouse gases. These 

workgroups addressed: (1) Fossil Fuel Combustion: Stationary, (2) Fossil Fuel Combustion: 

Mobile, (3) Fuel Suppliers, (4) Industrial Processes, (5) Industrial GHG Suppliers, (6) Fossil 

Fuel Fugitive Emissions, and (7) Biological Processes. An eighth workgroup developed the 

electronic data reporting system. The Climate Change Division within the Office of Atmospheric 

Programs coordinated the eight workgroups.

Prior to developing the proposed 2009 rule, each of the workgroups performed a 

comprehensive review of existing voluntary and mandatory GHG reporting programs, as well as 

guidance documents for quantifying greenhouse gas emissions from specific sources. A list of 

these reviews can be found in Section 3(a) above. The workgroups also reviewed international 

programs, including the IPCC, the EU Emissions Trading System, the Australian GHG 

Reporting System, and the Canadian Mandatory Greenhouse Gas Reporting Program.

In reviewing these programs, EPA analyzed the sectors covered, reporting thresholds, 

monitoring or emissions estimating methods used, quality assurance measures, the point of 

monitoring, data input needs, and information that respondents must report or retain.

During the development of the GHG Reporting Rule, EPA conducted a proactive 

communications outreach program to inform the public about the rule development effort. Prior 

to the proposal signature, EPA staff held more than 100 meetings with stakeholders, including:

 Trade associations and firms in potentially affected industries/sectors;
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 State, local, and tribal environmental control agencies and regional air quality

planning organizations;

 State and regional organizations already involved in GHG emissions reporting, such 

as The Climate Registry, California Air Resources Board, and the Western Climate 

Initiative; and

 Environmental groups and other nongovernmental organizations.

EPA also met with federal agencies, including DOE and the U.S. Department of 

Agriculture, which have programs relevant to GHG emissions.

After the proposed GHG Reporting Rule was signed on March 10, 2009 (74 FR 16448;

April 10, 2009), EPA held two public hearings, received approximately 16,800 written public 

comments, and met with over 4,000 people and 135 groups. Details of these meetings are 

available in the docket (EPA-HQ-OAR-2008-0508).

EPA has been continuously updating the GHGRP and providing technical corrections

based on feedback. Specifically, EPA has been working closely with owners and operators of 

facilities subject to the GHGRP to communicate reporting requirements. Through these 

discussions, EPA has identified specific sections of the GHGRP that were either not clear or did 

not have the intended effect. EPA has amended specific provisions to resolve issues raised 

during implementation and to correct technical and editorial errors that have been identified 

since publication. Some of these amendments affected burden, but most amendments reduced 

burden or did not affect it.

In addition to correcting and clarifying existing requirements, EPA has amended the 

GHGRP in other ways based on public comments and stakeholder feedback, e.g., promulgated 

rulemakings that re-propose certain subparts, added requirements for new facilities and suppliers,

and added reporting requirements that provide information about parent companies. Each action 

has had separate ICRs at noted in Appendix A.

3(d) Effects of Less Frequent Collection

The reporting frequency for emissions data to EPA has been established to minimize the 

burden on owners and operators of affected facilities, while ensuring that the GHGRP collects 

facility-specific data of sufficient quality to achieve the Agency’s objectives. The GHGRP

requires annual reporting, except for a limited number of facilities that are already subject to 

more frequent reporting requirements.

EPA recognizes that the highest level U.S. parent company and primary NAICS code(s) 

may change more frequently than annually. However, EPA believes that the burden of requiring 

facilities to update these data elements on a more frequent basis, such as every time a facility’s 

highest level U.S. parent company, primary product(s), activity(s), or service(s) change, is 

greater than the benefit of obtaining that additional information. Therefore, EPA is only
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requiring these data elements annually, thus lessening the burden as much as possible while still 

gathering necessary information.

EPA needs the data quickly at the beginning of every reporting year in order to 

electronically verify it, publish it as authorized by the CAA, and use it for the purposes 

described. If the information collection were not carried out on this schedule, the Agency would 

not be able to develop an informed tracking system of trends in GHG emissions across the 

country. 

3(e) General Guidelines

This collection of information is consistent with all OMB guidelines under 5 CFR 

1320.6. However, although the GHGRP generally has a 3 year requirement for record retention, 

in limited cases the GHGRP requires that facilities retain records for longer than the 3 year 

retention period specified in the general information collection guidelines in 5 CFR 1320.6(f) of 

the OMB regulations implementing the Paperwork Reduction Act. This is because facilities or 

suppliers that have emissions or products with emissions less than 25,000 metric tons CO2e/year

for five years in a row or less than 15,000 metric tons CO2e/year for three years in a row may

cease reporting. Those that cease reporting must have records to cover those consecutive years of 

emissions and must retain such records for three years following the year that reporting was 

discontinued. EPA selected these two time frames and reporting thresholds because it allows 

these facilities or suppliers to stop reporting, but avoids the situation where a facility or supplier 

near this level would be constantly moving in and out of the reporting program due to small 

variations from one year to the next. EPA believes the additional three years of recordkeeping for 

these respondents is needed to resolve any possible questions about past emission estimates.

Thus, the additional record retention requirement of the rule adds no additional burden.

3(f) Confidentiality

Data collected under the GHGRP must be made available to the public unless the data 

qualify for confidential treatment under the CAA and EPA regulations. EPA typically makes 

confidentiality determinations under the CAA on a case-by-case basis under 40 CFR 2.301. Due 

to the large numbers of entities reporting under the GHGRP and the large number of data 

reporting elements, EPA concluded that case-by-case determinations would not result in a timely

release of emission data and other non-confidential data. EPA has issued guidance on what 

constitutes emissions data that cannot be considered CBI (956 FR 7042 –7043; February 21, 

1991). EPA protects CBI in accordance with regulations in 40 CFR Chapter 1, Part 2, Subpart B.

All information submitted to the Agency for which a claim of confidentiality is made is

safeguarded according to the final confidentiality determination published on May 26, 2011 (76 

FR 30782). These confidentiality determinations conclude which data reporting elements in 40 

CFR Part 98 were CBI, which were non-CBI, and which were emission data and therefore, under 

Section 114 of the CAA, ineligible for CBI protection. Under the special provisions for 40 CFR 

Part 98 data at 40 CFR 2.301(d), EPA has grouped data elements into data categories and 

generally made confidentiality determinations on a category basis for 34 source categories.

These 34 source categories represent all reporting year 2010 source categories and four reporting 
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year 2011 source categories (Subparts T, FF, II and TT). Additionally, EPA finalized 

confidential determinations for new data elements added to subparts II and TT (XX FR XXXX; 

DATE) and for GHGRP data elements in subparts L, DD, QQ, RR, SS, and UU (XX FR XXXX; 

DATE), subpart I (XX FR XXXX; DATE), and subpart W (XX FR XXXX; DATE).

EPA has deferred the reporting deadline for data elements that are used as inputs to 

emissions equations to provide EPA time needed to fully evaluate and resolve issues regarding 

the reporting and potential release of these data (76 FR 53057; August 25, 2011). EPA has 

deferred the deadline for reporting some inputs to emissions equations until March 2013 and the 

deadline for others until March 2015 (77 FR 11039; February 24, 2012).

3(g) Sensitive Questions

This information collection does not ask any questions concerning sexual behavior or

attitudes, religious beliefs, or other matters usually considered private.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

The respondents in this information collection include owners and operators of facilities 

that must report their GHG emissions to EPA to comply with the rulemaking. To facilitate the 

analysis, EPA has divided respondents into groups that align with the source categories identified 

in the rule.

This section lists the industry sectors (i.e., GHG source categories) that must participate 

in the GHGRP, the data items required of program participants, and the activities in which 

participants must engage to collect, assess, and in some cases submit the required data items.

4(a) Respondents/North American Industrial Classification Systems (NAICS) Codes

Reporting facilities include, but are not limited to, those operating one or more units that 

exceed the CO2e threshold for the industry sectors listed below or those in the categories in 

which all must report, such as petroleum refining facilities and all other large emitters listed in 

Table A-3 of 40 CFR 98.2(a)(1). Additionally, the GHGRP also requires reporting of certain 

emissions information associated with mobile sources (e.g., for permit applications or emissions 

control certification testing procedures).

Industry sectors are listed below by their corresponding subpart of the rule and their 

NAICS code for reference.
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Part and Subpart NAICS code(s)

Parts 86, 87, 89, 90, 94, 

1033, 1039, 1042, 1045, 

1048, 1051, 1054, 1064, 

1065

481 Air transportation; 482 Rail transportation; 483 Water 

transportation

Part 98

C. General Stationary 

Fuel Combustion 

Sources

Facilities operating boilers, process heaters, incinerators, 

turbines, and internal combustion engines: 211 Extractors of 

crude petroleum and natural gas; 321 Manufacturers of lumber 

and wood products; 322 Pulp and paper mills; 325 Chemical 

manufacturers; 324 Petroleum refineries, and manufacturers of 

coal products; 316, 326, 339 Manufacturers of rubber and 

miscellaneous plastic products; 331 Steel works, blast furnaces; 

332 Electroplating, plating, polishing, anodizing, and coloring; 336 

Manufacturers of motor vehicle parts and accessories; 221 

Electric, gas, and sanitary services; 622 Health services; 611 

Educational services

D. Electricity Generation 221112 Fossil-fuel fired electric generating units, including units 

owned by federal and municipal governments and units located 

in Indian Country

E. Adipic Acid Production 325199 Adipic acid manufacturing facilities

F. Aluminum Production 331312 Primary Aluminum production facilities

G. Ammonia 

Manufacturing

325311 Anhydrous and aqueous ammonia manufacturing 

facilities

H. Cement Production 327310 Portland Cement manufacturing plants

I. Electronics 

Manufacturing

334111 Microcomputers manufacturing facilities; 334413 

Semiconductor, photovoltaic cells (PV) (solid-state) device 

manufacturing facilities; 334419 Liquid crystal display (LCD) unit 

screens manufacturing facilities; 334419 

Microelectricomechanical devices (MEMS) manufacturing 

facilities

K. Ferroalloy Production 331112 Ferroalloys manufacturing facilities

L. Fluorinated GHG 

Production

325120 Industrial gases manufacturing facilities

N. Glass Production 327211 Flat glass manufacturing facilities; 327213 Glass 

container manufacturing facilities; 327212 Other pressed and 

blown glass and glassware manufacturing facilities

O. HCFC-22 Production

and HFC-23 Destruction

325120 Chlorodifluoromethane manufacturing facilities

P. Hydrogen Production 325120 Hydrogen manufacturing facilities

Q. Iron and Steel 

Production

331111 Integrated iron and steel mills, steel companies, sinter 

plants, blast furnaces, basic oxygen process furnace (BOPF) shops

R. Lead Production 331419 Primary lead smelting and refining facilities; 331492 

Secondary lead smelting and refining facilities

S. Lime Manufacturing 327410 Calcium oxide, calcium hydroxide, dolomitic hydrates 

manufacturing facilities
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Part and Subpart NAICS code(s)

T. Magnesium 

Production 

331419 Primary refiners of nonferrous metals by electrolytic 

methods; 331492 Secondary magnesium processing plants

U. Miscellaneous Uses of 

Carbonate

Facilities included elsewhere

V. Nitric Acid Production 325311 Nitric acid manufacturing facilities

W. Petroleum and 

Natural Gas Systems

486210 Pipeline transportation of natural gas; 221210 Natural 

gas distribution facilities; 211 Extractors of crude petroleum and 

natural gas; 211112 Natural gas liquid extraction facilities

X. Petrochemical 

Production

32511 Ethylene dichloride manufacturing facilities; 325199 

Acrylonitrile, ethylene oxide, methanol manufacturing facilities; 

325110 Ethylene manufacturing facilities; 325182 Carbon black 

manufacturing facilities

Y. Petroleum Refineries 324110 Petroleum refineries

Z. Phosphoric Acid 

Production

325312 Phosphoric acid manufacturing facilities

AA. Pulp and Paper 

Manufacturing

322110 Pulp mills; 322121 Paper mills; 322130 Paperboard mills

BB. Silicon Carbide 

Production

327910 Silicon carbide abrasives manufacturing facilities

CC. Soda Ash 

Manufacturing

325181 Alkalis and chlorine manufacturing facilities, 212391 Soda 

ash, natural, mining and/or beneficiation

DD. Electrical Equipment 

Use

221121 Electric bulk power transmission and control facilities

EE. Titanium Dioxide 

Production

325188 Titanium dioxide manufacturing facilities

FF. Underground Coal 

Mines

212113 Underground anthracite coal mining operations; 212112 

Underground bituminous coal mining operations

GG. Zinc Production 331419 Primary zinc refining facilities; 331492 Zinc dust 

reclaiming facilities, recovering from scrap and/or alloying 

purchased metals

HH. Municipal Solid 

Waste Landfills

562212 Solid waste landfills; 221320 Sewage Treatment Facilities

II. Industrial Wastewater 

Treatment

322110 Pulp mills; 322121 Paper mills; 322122 Newsprint mills; 

322130 Paperboard mills; 311611 Meat processing facilities; 

311411 Frozen fruit, juice, and vegetable manufacturing facilities; 

311421 Fruit and vegetable canning facilities; 325193 Ethanol 

manufacturing facilities; 324110 Petroleum refineries

JJ. Manure Management Note: EPA will not be implementing subpart JJ of 40 CFR Part 98 

using funds provided in the Consolidated Appropriations Act, 

2012 (Public Law 112-74), due to a Congressional restriction 

prohibiting the expenditure of funds for this purpose.

LL. Suppliers of Coalbased Liquid Fuels211111 Coal liquefaction at mine sites

MM. Suppliers of 

Petroleum Products

324110 Petroleum refineries
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Part and Subpart NAICS code(s)

NN. Suppliers of Natural 

Gas and Natural Gas 

Liquids

221210 Natural gas distribution facilities; 211112 Natural gas 

liquid extraction facilities

OO. Suppliers of 

Industrial Greenhouse 

Gases

325120 Industrial greenhouse gas manufacturing facilities

PP. Suppliers of Carbon 

Dioxide

325120 Industrial greenhouse gas manufacturing facilities

QQ. Importers and 

Exporters of Pre-charged 

Equipment and ClosedCell Foams

423730 Air-conditioning equipment (except room units) 

merchant wholesalers; 333415 Air-conditioning equipment 

(except motor vehicle) manufacturing; 336391 Motor vehicle airconditioning manufacturing; 423620 Air-conditioners, room, 

merchant wholesalers; 443111 Household Appliance Stores; 

423730 Automotive air-conditioners merchant wholesalers; 

326150 Polyurethane foam products manufacturing; 335313 

Circuit breakers, power, manufacturing; 423610 Circuit breakers 

merchant wholesalers

RR. Geologic 

Sequestration of Carbon 

Dioxide

211 Oil and gas extraction projects using CO2 enhanced oil and 

gas recovery; 211111 or 211112 Projects that inject acid gas 

containing CO2 underground; N/A CO2 geologic sequestration 

projects

SS. Electrical Equipment 

Manufacture or 

Refurbishment

33531 Power transmission and distribution switchgear and 

specialty transformers manufacturing facilities

TT. Industrial Waste 

Landfills

562212 Solid waste landfills; 322110 Pulp mills; 322121 Paper 

mills; 322122 Newsprint mills; 322130 Paperboard mills; 311611 

Meat processing facilities; 311411 Frozen fruit, juice, and 

vegetable manufacturing facilities; 311421 Fruit and vegetable 

canning facilities; 221320 Sewage treatment facilities

UU. Injection of Carbon 

Dioxide

211 Oil and gas extraction projects using CO2 enhanced oil and 

gas recovery; 211111 or 211112 Projects that inject acid gas 

containing CO2 underground

Mobile Sources 333618 Heavy-duty, non-road, aircraft, locomotive, and marine 

diesel engine manufacturing; 336312 Small non-road, and marine 

spark-ignition engine manufacturing facilities; 336999 Personal 

watercraft manufacturing facilities; 336991 Motorcycle 

manufacturing facilities

Note: EPA will not be implementing subpart JJ of 40 CFR Part 98 using funds provided in the 

Consolidated Appropriations Act, 2012 (Public Law 112-74), due to a Congressional restriction 

prohibiting the expenditure of funds for this purpose.

4(b) Information Requested

(i) Data Items

Reporting Requirements
ICR for the GHGRP, DRAFT Page 14 May 2012

The GHGRP applies to certain facilities that emit GHGs and to suppliers of products that 

release GHGs if combusted, oxidized, or used. Applicability depends on the source categories 

located at the facility and, for some source categories, the emission level or production capacity. 

Fossil fuel and industrial GHG suppliers, motor vehicle and engine manufacturers, and facilities 

that emit 25,000 metric tons or more of CO2e/year report GHG emissions data to EPA annually.

Specifically, the facilities in the source list of Table A-3 of 40 CFR 98.2(a)(1) are the large 

emitters and subject to an all-in threshold, in which they report emissions regardless of a 

CO2e/year emissions threshold. These large emitters report all emissions from all-in emission 

source categories (Table A-3) as well as threshold source categories (Table A-4 of 40 CFR 

98.2(a)(2) source list), stationary fuel combustion sources (subpart C), and miscellaneous use of 

carbonates (subpart U). Suppliers in the source list of Table A-5 of 40 CFR 98.2(a)(4) report all 

applicable products in Table A-5.

In addition, facilities that do not contain sources listed in Table A-3, but that emit at least 

25,000 metric tons CO2e/year in combined emissions from stationary combustion sources and 

other sources listed in Table A-4 report emissions from stationary fuel combustion sources 

(subpart C), miscellaneous use of carbonates (subpart U), and all applicable source categories

listed in Table A-4. Facilities with only combustion emissions that emit at least 25,000 metric 

tons CO2e/year are only required to report emissions from combustion sources.

Respondents comply with the following categories of requirements (if applicable): the

General Provisions applicable to all sources; stationary combustion; and requirements applicable 

to other specific source categories identified in subparts D through UU of the rule. In addition, 

vehicle and engine manufacturers subject to the requirements of CFR parts 86, 87, 89, 90, 94, 

1033, 1039, 1042, 1045, 1048, 1051, 1054, and 1065 report CO2, N2O, and CH4 emissions 

associated with the mobile sources that they produce.

The following is a summary of the information requested by source category; requirements 

that apply to specific sources are found in Appendix A (reporting requirements) and Appendix B 

(recordkeeping requirements).

General requirements that apply to all sources. All respondents that exceed the 

reporting threshold or that belong to a source category in which all respondents report submit the 

following information electronically:

1. Facility name or supplier name (as appropriate), and physical street address of the 

facility or supplier, including the city, State, and zip code.

2. Year and months covered by the report;

3. Date of submittal;

4. For facilities, except as otherwise provided in 40 CFR 98.3(c)(12), annual emissions 

of CO2, CH4, N2O, and each fluorinated GHG (as defined in 40 CFR 98.6) as follows:

a. Annual emissions (excluding biogenic CO2) aggregated for all GHG from 

all applicable source categories and expressed in metric tons of CO2e 

calculated using Equation A-1 provided in subpart A;
ICR for the GHGRP, DRAFT Page 15 May 2012

b. Annual emissions of biogenic CO2 aggregated for all applicable source 

categories, expressed in metric tons;

c. Annual emissions from each applicable source category, expressed in 

metric tons of each GHG listed as follows: i) Biogenic CO2; ii) CO2

(excluding biogenic CO2); iii) CH4; iv); N2O; and v) Each fluorinated 

GHG (including those not listed in Table A-1 of subpart A).

d. Except as provided in 40 CFR 98.2(c)(4)(vii), emissions and other data for 

individual units, processes, activities, and operations as specified in the 

“Data reporting requirements” section of each applicable subpart.

e. Emissions and other data for individual units, processes, activities, and 

operations as specified in the “Data reporting requirements” section of 

each applicable subpart.

f. Indicate (yes or no) whether reported emissions include emissions from a 

cogeneration unit located at the facility.

g. When applying 40 CFR 98.2(c)(4)(i) to fluorinated GHGs, calculate and 

report CO2e for only those fluorinated GHGs listed in Table A–1 of 

subpart A.

h. The owner or operator of a facility is not required to report the data 

elements specified in Table A–6 of subpart A for calendar years 2010 

through 2011 until March 31, 2013. The owner or operator of a facility is 

not required to report the data elements specified in Table A–7 of subpart 

A for calendar years 2010 through 2013 until March 31, 2015.

5. For suppliers, annual quantities of CO2, CH4, N2O, and each fluorinated GHG (as 

defined in 40 CFR 98.6) that would be emitted from combustion or use of the 

products supplied, imported, and exported during the year. Calculate and report 

quantities at the following levels:

a. Total quantity of GHG aggregated for all GHG from all applicable supply

categories in Table A–5 of subpart A and expressed in metric tons of CO2e 

calculated using Equation A–1 of subpart A. For fluorinated GHGs, 

calculate and report CO2e for only those fluorinated GHGs listed in Table 

A–1 of subpart A;

b. Quantity of each GHG from each applicable supply category in Table A–5 

of subpart A, expressed in metric tons of each GHG. For fluorinated GHG, 

report emissions of all fluorinated GHG, including those not listed in 

Table A-1 of subpart A; and

c. Any other data specified in the “Data reporting requirements” section of 

each applicable subpart. 

6. A written explanation, as required under 40 CFR 98.3(e), if emission calculation 

methodologies are changed during the reporting period.

7. A brief description of each “best available monitoring method,” the parameters

measured using the method, and the time period during which the “best available 

monitoring method” was used, if applicable.

8. Each data element for which a missing data procedure was used according to the 

procedures of an applicable subpart and the number of hours in the year that a 

missing data procedure was used for each data element.
ICR for the GHGRP, DRAFT Page 16 May 2012

9. A signed and dated certification statement provided by the designated representative 

of the owner or operator, according to the requirements of 40 CFR 98.4(e)(1).

10. NAICS code(s) that apply to the facility or supplier.

a. Primary NAICS code. Report the NAICS code that most accurately

describes the facility or supplier's primary product/activity/service. The 

primary product/activity/service is the principal source of revenue for the 

facility or supplier. A facility or supplier that has two distinct 

products/activities/services providing comparable revenue may report a 

second primary NAICS code.

b. Additional NAICS code(s). Report all additional NAICS codes that 

describe all product(s)/activity(s)/service(s) at the facility or supplier that 

are not related to the principal source of revenue.

11. Legal name(s) and physical address(es) of the highest-level United States parent 

company(s) of the owners (or operators) of the facility or supplier and the percentage 

of ownership interest for each listed parent company as of December 31 of the year 

for which data are being reported according to the following instructions:

a. If the facility or supplier is entirely owned by a single United States 

company that is not owned by another company, provide that company's 

legal name and physical address as the United States parent company and 

report 100 percent ownership.

b. If the facility or supplier is entirely owned by a single United States 

company that is, itself, owned by another company (e.g., it is a division or 

subsidiary of a higher-level company), provide the legal name and 

physical address of the highest-level company in the ownership hierarchy 

as the United States parent company and report 100 percent ownership.

c. If the facility or supplier is owned by more than one United States 

company (e.g., company A owns 40 percent, company B owns 35 percent, 

and company C owns 25 percent), provide the legal names and physical 

addresses of all the highest-level companies with an ownership interest as 

the United States parent companies, and report the percent ownership of 

each company.

d. If the facility or supplier is owned by a joint venture or a cooperative, the 

joint venture or cooperative is its own United States parent company. 

Provide the legal name and physical address of the joint venture or 

cooperative as the United States parent company, and report 100 percent 

ownership by the joint venture or cooperative.

e. If the facility or supplier is entirely owned by a foreign company, provide 

the legal name and physical address of the foreign company's highest-level 

company based in the United States as the United States parent company, 

and report 100 percent ownership.

f. If the facility or supplier is partially owned by a foreign company and 

partially owned by one or more U.S. companies, provide the legal name 

and physical address of the foreign company's highest-level company 

based in the United States, along with the legal names and physical 

addresses of the other U.S. parent companies, and report the percent 

ownership of each of these companies.
ICR for the GHGRP, DRAFT Page 17 May 2012

g. If the facility or supplier is a federally owned facility, report “U.S. 

Government” and do not report physical address or percent ownership.

Under 40 CFR 98.3(h), the owner or operator submits a revised report within 45 days of 

discovering that an annual GHG report that the owner or operator previously submitted contains 

one or more substantive errors or being notified by EPA of errors in its GHG report. The revised 

report must correct all substantive errors.

Under 40 CFR 98.4(d), the designated representative submits the certificate of representation at 

least 60 days before the report deadline. Under 40 CFR 98.4(i), the certificate of representation 

includes:

1. An identification of the facility or supplier for which the certificate of representation 

is submitted;

2. The name, organization name (company affiliation-employer), address, e-mail 

address (if any), telephone number, and facsimile transmission number (if any) of the 

designated representative and any alternate designated representative;

3. A list of the owners and operators of the facility or supplier, provided that, if the list 

includes the operators of the facility or supplier and the owners with control of the 

facility or supplier, the failure to include any other owners does not make the 

certificate of representation incomplete; 

4. The certification statements listed in 40 CFR 98.4(i)(4); and

5. The signature of the designated representative and any alternate designated 

representative and the dates signed.

The GHGRP also includes notification procedures for changing a designated representative or 

alternate designated representative (40 CFR 98.4(g)).

Under 40 CFR 98.4(m)(2), in order to delegate his or her own authority to one or more 

individuals to submit an electronic submission of the GHG reports, the designated representative 

or alternate designated representative submits electronically to the Administrator a notice of 

delegation that includes the following elements:

1. The name, organization name (company affiliation-employer) address, e-mail address 

(if any), telephone number, and facsimile transmission number (if any) of such 

designated representative or alternate designated representative.

2. The name, address, e-mail address, telephone number, and facsimile transmission 

number (if any) of each such individual (referred to as an “agent”).

3. For each such individual, a list of the type or types of electronic submissions under 40 

CFR 98.4(m)(1) for which authority is delegated to him or her.

4. For each type of electronic submission listed in accordance with clause (iii), the 

facility or supplier for which the electronic submission may be made.

5. The certification statements in 40 CFR 98.4(m)(2)(v). 

6. The signature of such designated representative or alternate designated representative 

and the date signed. 
ICR for the GHGRP, DRAFT Page 18 May 2012

Facilities that may discontinue reporting. Under 98.2(i), if reported emissions are less 

than 25,000 metric tons CO2e/year for five consecutive years or less than 15,000 metric tons 

CO2e/year for three consecutive years, then the owner or operator may discontinue complying 

provided that the owner or operator submits a notification to the Administrator that announces 

the cessation of reporting and explains the reasons for the reduction in emissions. The owner or 

operator maintains the corresponding records required under 40 CFR 98.3(g) for the five (or 

three) consecutive years and then retain such records for three years following the year that 

reporting was discontinued.

If the operations of a facility or supplier are changed such that all applicable GHG-emitting 

processes and operations cease to operate, then the owner or operator is exempt from reporting in 

the years following the year in which cessation of such operations occurs, provided that the 

owner or operator submits a notification to the Administrator that announces the cessation of 

reporting and certifies to the closure of all GHG-emitting processes and operations. This does not 

apply to seasonal or other temporary cessation of operations or facilities with municipal solid 

waste landfills, industrial waste landfills, or underground coal mines. The owner or operator 

resumes reporting for any future calendar year during which any of the GHG-emitting processes 

or operations resume operation.

Other source categories. Facilities that contain any of the source categories listed in 

Section 4(a) and that exceed the threshold for any source category (or include a source category

in which all facilities report) report information specific to each source category at the facility for 

which methods are specified in 40 CFR Part 98, in addition to the general reporting and 

stationary combustion requirements outlined above. Many facilities that are affected by the 

GHGRP emit GHGs from multiple sources.

The sector-specific reporting requirements are outlined in Appendix B.
ICR for the GHGRP, DRAFT Page 19 May 2012

Recordkeeping Requirements

General requirements that apply to all sources. The owner or operator of each facility

that is subject to the GHG emissions reporting requirements keeps the following records for at 

least three years from the date of submission of the annual GHG report for the reporting year in 

which the record was generated. Upon request by the Administrator, the records required under 

this section must be made available to EPA. Records may be retained off site if the records are 

readily available for expeditious inspection and review. For records that are electronically 

generated or maintained, the equipment or software necessary to read the records shall be made 

available, or, if requested by EPA, electronic records shall be converted to paper documents.

1. A list of all units, operations, processes, and activities for which GHG emissions were 

calculated.

2. The data used to calculate the GHG emissions for each unit, operation, process, and 

activity, categorized by fuel or material type, including: (i) The GHG emissions 

calculations and methods used; (ii) Analytical results for the development of sitespecific emissions factors; (iii) The results of all required analyses for high heat value, 

carbon content, and other required fuel or feedstock parameters; and (iv) Any facility

operating data or process information used for the GHG emission calculations. 

3. The annual GHG reports.

4. Missing data computations. For each missing data event, respondents must maintain 

records of the cause of the event and the corrective actions taken to restore 

malfunctioning monitoring equipment.

5. A written GHG Monitoring Plan, which must include, at a minimum, the following: (i)

Identification of positions of responsibility (i.e., job titles) for collection of the 

emissions data; (ii) Explanation of the processes and methods used to collect the 

necessary data for the GHG calculations; and (iii) Description of the procedures and 

methods that are used for quality assurance, maintenance, and repair of all continuous 

monitoring systems, flow meters, and other instrumentation used to provide data for the 

GHGs reported.

a. The owner or operator must revise the GHG Monitoring Plan as needed to reflect 

changes in production processes, monitoring instrumentation, and quality assurance 

procedures; or to improve procedures for the maintenance and repair of monitoring 

systems to reduce the frequency of monitoring equipment downtime. 

b. Upon request by the Administrator, the owner or operator must make all 

information that is collected in conformance with the GHG Monitoring Plan 

available for review during an audit. Electronic storage of the information in the 

plan is permissible, provided that the information can be made available in hard 

copy upon request during an audit.

6. The results of all required certification and quality assurance tests of continuous 

monitoring systems, fuel flow meters, and other instrumentation used to provide data 

for the GHGs reported.

7. Maintenance records for all continuous monitoring systems, flow meters, and other 

instrumentation used to provide data for the GHGs reported under 40 CFR 98.
ICR for the GHGRP, DRAFT Page 20 May 2012

Other source categories. Facilities that report and that contain any of the source 

categories listed in Section 4(a) also retain records for information specific to the given source 

category. The sector-specific recordkeeping requirements are outlined in Appendix C.

(ii) Respondent Activities

The owner or operator of a facility that is subject to the GHGRP’s reporting requirements

reports total annual GHG emissions in metric tons of CO2e, as applicable. The primary tasks that 

reporting program respondents perform include:

1. Implement and update, as necessary, appropriate monitoring plans for each affected 

source and each affected unit at a source, as applicable;

2. Operation and maintenance activities associated with the monitoring, including 

quality assurance activities; 

3. Ensuring data quality, preparing annual reports for submission to EPA, and 

submitting these reports to EPA; 

4. Potentially responding to questions or error messages from EPA; and 

5. Maintaining records for a minimum of three years.

Respondents that use CEMS also conduct tests to certify the operations of monitors, 

submit the results of these tests, and record emissions data (this activity generally is performed 

electronically).

Reports present the annual mass GHG emissions from each source category separately.

The calculations used to determine GHG emissions, the frequency at which those calculations 

are required, the methods used to estimate missing data, and the QA/QC requirements depend on 

the specific source category.

5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION 

METHODS, AND INFORMATION MANAGEMENT

5(a) Agency Activities

EPA Headquarters activities include the monitoring and verification of emission reports, 

database and software maintenance, communication and outreach, and program evaluation.

5(b) Collection Methodology and Management

EPA has established a central repository of inventory data for all respondents, the webbased Electronic Greenhouse Gas Reporting Tool (e-GGRT). Respondents report data 

electronically, and EPA stores the data in the database. Facilities and suppliers subject to the 

GHGRP register online through the e-GGRT system.

All data is submitted to EPA electronically in e-GGRT except the one-time Electronic 

Signature Agreement (ESA) which is submitted on paper. The tool has an XML reporting 
ICR for the GHGRP, DRAFT Page 21 May 2012

schema that allows facilities to upload GHG data directly in lieu of using the web forms provided 

through e-GGRT. The XML reporting schema contains all of the data elements needed to 

comply with the GHGRP. The electronic reports submitted under the GHGRP are subject to the 

provisions of 40 CFR Part 3, specifying EPA systems to which electronic submissions must be 

made and the requirements for valid electronic signatures. Additionally, E-GGRT can handle 

CBI.

The new system follows Agency standards for design, security, data element and 

reporting format conformance, and accessibility. EPA designed the database in an attempt to 

minimize respondents’ burden by integrating the new reporting requirements with existing data 

collection and data management systems, when feasible. 

All facilities or suppliers must have a Designated Representative (DR) in order to report. 

The DR may appoint an Alternative Designated Representative (ADR) and agents. The DR, 

ADR, and agent are all able to enter data and submit the electronic report. Before submitting a 

report, the DR (or ADR) must certify the annual report. An electronic signature device (e.g., a 

PIN or password) is required to submit a report.

5(c) Small Entity Flexibility

EPA took several steps to minimize the impacts on small entities. The Agency met 

several times with industry trade associations to discuss the reporting options considered and 

their possible impacts on small entities. EPA further minimized impacts on small entities by not 

requiring facilities below a certain emissions threshold to report their emissions.

Where feasible, EPA also uses existing GHG emissions estimation and reporting 

methodologies and provides simplified methodological options to reduce reporting burden.

According to the Agency’s analysis, a facility with stationary combustion units that have a 

maximum rated heat input capacity of less than 30 mmBtu/hr, operating full time with any type 

of fossil fuel, would not exceed 25,000 metric tons CO2e/year. Exempting facilities based on 

combustion unit capacity has allowed for small entities to perform a simple calculation to 

determine if they are even required to estimate emissions for applicability purposes.

Additionally, EPA minimized the impact on small entities in subpart NN (Suppliers of 

Natural Gas and Natural Gas Liquids) by amending the reporting threshold from an all-in 

threshold to a capacity-based threshold. EPA revised the applicability threshold so that only local 

distribution companies (LDCs) that deliver 460,000 thousand standard cubic feet (mscf) or more 

of natural gas per year are subject to the GHGRP (75 FR 79092; December 17, 2010).

The rule includes a mechanism in 40 CFR 98.2 to allow facilities and suppliers that report 

less than 25,000 metric tons of CO2e/year for 5 years or less than 15,000 metric tons CO2e/year 

for 3 years to cease annual reporting to EPA. 
ICR for the GHGRP, DRAFT Page 22 May 2012

5(d) Collection Schedule

Facilities collect data and calculate emissions at varying frequencies, as described in the 

GHGRP, and summarized in Appendix B. Most facilities that meet the GHGRP’s reporting 

requirements submit GHG emission reports annually.

Facilities report all U.S. parent company(s) information and facility primary NAICS 

code(s) annually. EPA requires that the US parent company(s) and NAICS code(s) be reported as 

of December 31st of the reporting year, to remain consistent with the other requirements of the 

GHGRP.

A facility or supplier that becomes subject to the GHGRP because of a physical or 

operational change report emissions for the first calendar year in which the change occurs 

beginning with the first month of the change. A facility or supplier that becomes subject to the 

GHGRP solely because of an increase in hours of operation or level of production reports

emissions beginning the first month of the change if it would cause the facility or supplier to 

exceed the applicable threshold if maintained for the remainder of the year. 

Facilities or suppliers that have emissions or products with emission less than 25,000 

metric tons of CO2e for five years in a row or less than 15,000 metric tons of CO2e for three 

years in a row may discontinue complying provided that the owner or operator submits a 

notification to the Administrator that announces the cessation of reporting and explains the 

reasons for the reduction in emissions. The notification must be submitted no later than March 31 

of the year immediately following the fifth (or third) consecutive year of emissions less than 

25,000 (or 15,000) tons CO2e/year. The owner or operator must maintain the corresponding 

records required under 40 CFR 98.3(g) for each of the five (or three) consecutive years and 

retain such records for three years following the year that reporting was discontinued. The owner 

or operator must resume reporting if annual emissions in any future calendar year increase to 

25,000 (or 15,000) metric tons CO2e/year or more.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

This section presents EPA’s estimates of the burden and costs to respondents associated 

with the activities described in Section 4 as well as the federal burden hours and costs associated 

with the activities described in Section 5(a). EPA estimates that, over the three years covered by

this request, the total respondent burden associated with this reporting will average 900 thousand 

hours per year and the cost of all respondents of the information collection will average $84.2

million per year.

Section 6(a) of this ICR provides estimates of burden (hours) for all respondent types.

Section 6(b) contains estimates of respondent costs for the information collection. Section 6(c) 

summarizes federal burden and costs. Section 6(d) describes the respondent universe and the 

total burden and cost of this collection to respondents. Section 6(e) presents the bottom line 

burden and cost. Section 6(f) provides reasons for any change in burden. The burden statement 

for this information collection is in Section 6(g). 
ICR for the GHGRP, DRAFT Page 23 May 2012

6(a) Estimating Respondent Burden

Respondent burden estimates are presented in Exhibit 6.1. EPA estimates that the total 

annual burden to all affected entities is 942,344 hours per year over the three years covered by

this information collection. EPA also estimated the number of responses, or actions taken as a 

result of the rule, per respondent (facility) per year; for facilities collecting samples on a daily 

basis, this means a minimum of 365 responses per year. Exhibit 6.1 presents aggregate burden by

sector only; for the details of burden calculations, please see the cost appendices.

6(b) Estimating Respondent Costs

Costs to respondents associated with this information collection include labor costs (i.e., 

the cost of labor by facility staff to meet the rule’s information collection requirements) and nonlabor costs (e.g., the cost of purchasing and installing monitoring equipment or contractor costs 

associated with providing the required information).

To calculate labor costs, EPA estimated technical, managerial, clerical, and legal loaded 

labor rates for each industry sector using labor rates from the Bureau of Labor Statistics[1. For all 

subparts the labor rates are: $59.12 for technical workers, $77.23 for managers, $31.35 for 

clerical support, and $109.94 for legal support. Non-labor costs (capital and O&M) for individual 

sectors are summarized in Exhibit 6-1.

EPA estimates that the total annual cost to all affected non-federal entities is $84.2

million over the three years covered by this information collection. Exhibit 6.1 presents

aggregate costs by sector only; for the details of EPA’s cost calculations, please see Appendix C.

 

[1] May 2011 National Industry-Specific Occupational Employment and Wage Estimates

(http://www.bls.gov/oes/current/oessrci.htm) and Employer Costs for Employee Compensation for June of 2011 

(http://www.bls.gov/news.release/archives/ecec_09082011.pdf). See Appendix D for more information. 
ICR for the GHGRP, DRAFT Page 24 May 2012

Exhibit 6.1 Annual Average Respondent Burden and Cost

For the GHG Reporting Program ($K)

Source Category

No. 

Respondents

Responses/

Respondent

Total 

Responses

Total 

Burden 

(hrs)

Total Labor 

Cost

($K)

Capital 

Cost 

($K)

O&M Cost

 ($K)

Total Cost

($K)

C. Stationary Combustion 

(general unspecified) 2,568 40 102,184 258,675 $15,304 $820 $2,366 $18,490

D. Electricity Generation 1,259 9 9,815 68,171 $4,035 $0 $0 $4,035

E. Adipic Acid Prod. 3 28 84 555 $33 $0 $25 $58

F. Aluminum Production 12 17 198 3,604 $232 $0 $3 $235

G. Ammonia Manufacturing 22 107 2,355 2,150 $129 $1 $129 $259

H. Cement Production 98 510 50,007 28,152 $1,698 $546 $1,681 $3,925

I. Electronics Manufacturing 94 7 662 35,001 $2,055 $3,512 $0 $5,567

K. Ferroalloy Production 10 99 987 821 $48 $0 $16 $65

L. Fluorinated Greenhouse Gas 

Prod 14 7 99 2,601 $142 $33 $14 $190

N. Glass Production 106 102 10,816 8,506 $508 $0 $107 $615

O. HCFC-22 Production and HFC23 Destruction 5 92 460 768 $42 $0 $0 $42

P. Hydrogen Production 46 23 1,057 3,428 $203 $0 $87 $290

Q. Iron and Steel Production 122 92 11,229 35,158 $1,848 $0 $275 $2,123

R. Lead Production 12 102 1,224 1,053 $62 $0 $19 $81

S. Lime Manufacturing 70 544 38,083 15,312 $909 $422 $1,109 $2,439

T. Magnesium Production 11 9 99 2,061 $123 $0 $2 $124

U. Misc. Uses of Carbonate 0 0 0 0 $0.00 $0.00 $0.00 $0.00

V. Nitric Acid Production 37 42 1,557 6,728 $421 $14 $177 $613

W. Oil and Natural Gas Systems 2,786 8 21,201 229,624 $14,215 $730 $1,687 $16,631

X. Petrochemical Prod. 63 92 5,799 12,807 $737 $0 $582 $1,319

Y. Petroleum Refineries 146 92 13,438 57,512 $3,332 $173 $224 $3,728

Z. Phosphoric Acid Prod 10 544 5,440 2,187 $130 $60 $158 $348

AA. Pulp & Paper Mnfctrng 116 92 10,677 11,148 $655 $1,709 $43 $2,407

BB. Silicon Carbide Production 1 37 37 153 $9 $0 $0 $9

CC. Soda Ash Manufacturing 4 93 372 932 $57 $0 $7 $64

DD. Sulfur Hexafluoride (SF6) 

from Electric Power Systems 141 7 993 10,635 $596 $0 $0 $596

EE. Titanium Dioxide Production 7 93 651 1,091 $65 $0 $3 $68

FF. Underground Coal Mines 114 21 2,366 4,702 $274 $220 $456 $950

GG. Zinc Production 6 108 648 657 $39 $1 $5 $45

HH. Landfills 1,195 92 109,989 45,311 $2,611 $66 $127 $2,804

II. Wastewater 358 7 2,525 3,203 $188 $284 $1,017 $1,489

JJ. Manure Management (3) 107 91 9,801 4,643 $275 $1 $0 $276

LL. Suppliers of Coal-based 

Liquid Fuels, 

MM. Suppliers of Petrol. Prod. 315 99 31,057 13,375 $936 $0 $0 $936

NN. Supplies of Nat Gas and Nat 

Gas Liquids 474 53 25,240 31,095 $1,852 $0 $0 $1,852

OO. Suppliers of Industrial GHG 49 15 737 2,733 $163 $0 $0 $163

PP. Suppliers of CO2 130 36 4,685 5,882 $346 $0 $0 $346

QQ - Imports and Exports of 

Fluorinated GHGs in Products 158 7 1,112 11,063 $661 $0 $0 $661

RR. Geologic Sequestration of 

Carbon Dioxide 3 23 61 2,139 $125 $135 $327 $587

SS - SF6 Equipment Producers 10 7 70 441 $24 $0 $0 $24

TT -Industrial Landfills 200 8 1,608 13,493 $782 $11 $88 $881

UU. Injection of Carbon Dioxide 92 12 1,110 4,150 $241 $0 $208 $450

Mobile Sources 316 1 316 626 $36 $8,407 $0 $8,442

TOTAL 11,039 Varies 480,851 942,344 $56,141 $17,145 $10,941 $84,228

(2) EPA is in the process of reviewing the number of responses per respondent to ensure consistency in how burden is characterized among subparts. 

This analysis will not affect the total burden per subpart.

(1) Some respondents belong to multiple source categories, so the number of respondents is not additive.

(3) EPA will not be implementing Subpart JJ due to a Congressional restriction prohibiting the expenditure of funds for this purpose.
ICR for the GHGRP, DRAFT Page 25 May 2012

6(c) Estimating Agency Burden and Cost

This section describes the burden and cost to the federal government associated with this 

information collection. Federal activities under this information collection include EPA 

Headquarters oversight of the reporting program and required reporting by federally owned GHG 

generating facilities.

EPA Burden and Cost for Program Oversight 

EPA activities associated with the GHG reporting program include Headquarters 

oversight and implementation of the reporting program, e.g., monitoring and verification of 

emission reports, database and software maintenance, communication and outreach, and program 

evaluation. EPA estimates that Headquarters will devote between 20 and 30 full time equivalents 

(FTEs), or an estimated 52,000 hours to these activities.

To develop EPA labor costs, EPA estimates the average hourly labor rate for salary and 

overhead and benefits for Agency staff to be $52.37. To derive this figure, EPA multiplied the 

hourly compensation at GS-12, Step 5 on the 2011 GS pay scale ($32.73) by the standard 

government benefits multiplication factor of 1.6 to account for overhead and benefits.

In addition to the labor cost, EPA will incur a non-labor cost of approximately $10.7

million in each of the three years of the information collection for developing guidance, training, 

responding to stakeholders, communication and outreach, database maintenance, and other 

contractor support. 

Burden and cost for federal facilities covered by the rule

Federally owned facilities that exceed the CO2e threshold must report their GHG 

emissions. In 2010, federally owned facilities reported in Subparts C (Stationary Combustion, 

general unspecified), D (Electricity Generation), V (Nitric Acid Production), and HH (Landfills).

It is anticipated that federally owned facilities will also report under Subparts RR and UU 

(Sequestration of CO2, under which federally owned facilities are anticipated to seek exemptions, 

and Injection of CO2). EPA calculated the reporting burden and cost for these facilities in the 

same manner as it did for other reporting facilities. EPA estimates that the federal burden for 

these facilities is approximately 6,570 hours, for an annual total cost of $464,739.

Exhibit 6.2 presents the annual burden and cost for federal facilities that must comply

with the rule.
ICR for the GHGRP, DRAFT Page 26 May 2012

Exhibit 6.2 Annual Agency Burden and Cost

Information Collection Activity

Annual 

Responses

Total 

Annual 

Burden Labor Cost

Non-Labor 

Cost

Total Annual 

Cost

Guidance Development, Training,

Audits, and General Oversight 1 52,000 2,723,240 10,666,667 $13,389,907 

C. Stationary Combustion 

(general unspecified) 1950 4,936 $292,012 $60,792 $352,804 

D. Electricity Generation 148 1,029 $60,887 $0 $60,887 

V. Nitric Acid Production 42 182 $11,382 $5,174 $16,555 

HH. Landfills 92 228 $13,112 $965 $14,077 

RR. Geologic Sequestration of

Carbon Dioxide 1 16 $930 0 $930 

UU. Injection of CO2 4 180 $10,461 $9,024 $19,485 

TOTAL 2,238 58,570 3,112,025 10,742,621 13,854,646 

Burden for Compliance by Federal Facilities

Oversight

6(d) Estimating the Respondent Universe and Total Burden and Costs

The number of respondents in each sector that perform the required activities under this 

information collection is presented in Exhibit 6.1. The required activities depend on whether the 

facility must report its GHG emissions and on the applicable sector-specific reporting 

requirements. These activities are described in Section 4(b) of this ICR.

6(e) Bottom Line Burden Hours and Costs

The bottom line burden hours and costs are shown in Exhibit 6.3.
ICR for the GHGRP, DRAFT Page 27 May 2012

Exhibit 6.3 Bottom Line Annual Burden and Cost

Number of Respondents 11,290 From Exhibit 6.1

Total Annual Responses 480,851 From Exhibit 6.1

43 = 480,851 Total annual responses from above ÷

 11,290 Total respondents from above

Total Respondent Hours 942,344 From Exhibit 6.1

Hours per Response 1.96 = 942,344 Total annual hours from above ÷

 480,851 Total responses from above

Annual O&M and Capital Cost $28,086,090 From Exhibit 6.1

Total Respondent Cost (labor + non) $84,227,545 From Exhibit 6.1

 1,000,914 = 942,344 Total respondent hours from above +

 58,570 Total EPA hours from Exhibit 6-2

 98,082,191 = $84,227,545 Total respondent cost from above +

 $13,854,646 Total EPA cost from Exhibit 6-2

Number of Responses per Respondent

Total Hours (Respondents and Agency)

Total Cost (Respondents and Agency)

Note: Detail may not add exactly to total due to independent rounding

6(f) Reasons for Change in Burden

This section presents the change in burden and explains the reasons for the change in 

burden. Exhibit 6.4 summarizes the adjustments that have affected the overall burden inventory

for the final GHGRP ICRs.
ICR for the GHGRP, DRAFT Page 28 May 2012

Exhibit 6.4 Summary of Changes in Annual Burden 

Title

Current 

OMB Control 

Number 

Reference 

EPA ICR

Number(s)

No.

Respondents

Total Burden 

(hrs)

Total Labor 

Cost

($K)

Capital Cost

($K)

O&M Cost

 ($K)

Total Cost

($K)

Current Inventory 2060-0629

2300.03 - 

2300.09 16,408 1,024,285 $54,994 $8,770 $10,314 $74,079

Revised Inventory 6,742 618,043 $36,381 $3,813 $7,142 $47,335

Change -9,666 (406,242) -$18,614 -$4,957 -$3,173 -$26,743

Current Inventory 2060-0647

2396.01,

2396.02 683 65,958 $3,635 $515 $1,563 $5,713

Revised Inventory 683 22,996 $1,337 $515 $1,563 $3,415

Change 0 (42,962) -$2,298 $0 $0 -$2,298

Current Inventory 2060-0651

2376.02,

2376.03,

2376.05 2,786 394,757 $25,139 $745 $1,687 $27,570

Revised Inventory 2,786 227,738 $14,091 $730 $1,687 $16,508

Change 0 (167,019) -$11,048 -$15 $0 -$11,063

Current Inventory 2060-0650

2373.02 - 

2373.04 417 76,701 $4,152 $2,705 $10 $6,866

Revised Inventory 417 59,458 $3,461 $3,545 $14 $7,020

Change 0 (17,243) -$691 $841 $5 $154

“Track 1” Subparts, Not Including Mobile Sources (Subparts C, D, E, F, G, H, N, O, P, Q, R, S, U, V, X, Y, Z, AA, BB, CC, EE, GG, HH, JJ, LL, MM, NN,

OO, and PP)

Magnesium Production, Underground Coal Mines, Industrial Wastewater Treatment, and Industrial Waste Landfills (Subparts T, FF, II, and TT)*

Petroleum and Natural Gas Systems (Subpart W)*

Reason for Change in Burden (See Appendix G-3 for more details)

• Removed one-time burden for coverage determination, which affected 19,848 respondents, who incurred 258,019 hours in burden (over 

three years, this averaged 6,610 respondents and 86,006 hours). 

• Adjusted the number of respondents based on the number of facilities that reported to eGGRT. 

• Adjusted the labor hours, labor cost, O&M costs, and capital cost per facility to recognize the completion of the one-time activities that

occurred in the first year of data collection (2010).

Reason for Change in Burden (see Appendix H-3 for more details)

• Adjusted the labor hours and labor cost per facility to recognize the completion of the one-time activities that occurred in the first year of 

data collection (2011).

Reason for Change in Burden (see Appendix I-3 for more details):

• Adjusted the labor hours, labor cost, and O&M cost per facility to recognize the completion of the one-time activities that occurred in the

first year of data collection (2011).

• Corrected an error in the 2010 ICR, in which the burden hours for two activities were summed incorrectly (see Appendix F-3).

Additional Sources of Fluorinated GHG (Subparts I, L, DD, QQ, and SS)*

Reason for Change in Burden (see Appendix J-3 for more details):

• Adjusted the labor hours, labor cost, O&M costs, and capital cost per facility to recognize the completion of the one-time activities that

occurred in the first year of data collection (2011).

• Note: EPA is considering future amendments to Subpart I. These changes would be documented in a future ICR, which would amend this 

renewal ICR. 
ICR for the GHGRP, DRAFT Page 29 May 2012

Exhibit 6.4 Summary of Changes in Annual Burden (continued) 

Title

Current 

OMB Control 

Number 

Reference 

EPA ICR

Number(s)

No.

Respondents

Total Burden 

(hrs)

Total Labor 

Cost

($K)

Capital Cost

($K)

O&M Cost

 ($K)

Total Cost

($K)

Current Inventory 2060-0649

2372.02,

2372.03 89 4,794 $357 $88 $439 $884

Revised Inventory 93 6,224 $362 $135 $535 $1,033

Change 4 1,430 $5 $47 $96 $148

Current Inventory 2060-0646 2374.02 10,551 9,487 $571 $0 $0 $571

Revised Inventory 10,723 7,259 $475 $0 $0 $475

Change 172 (2,228) -$97 $0 $0 -$97

Current Inventory, Not 

Including Below 2060-0629 2300.03 317 140,680 $8,605 $0 $0 $8,605

Current Inventory, Aircraft 

Engines 2060-0680 2427.02 10 60 $3,646 $0 $0 $3,646

Revised Inventory 316 626 $36 $8,407 $0 $8,442

Change -11 (140,114) -$12,216 $8,407 $0 -$3,809

Current Inventory 20,710 1,707,234 $100,529 $12,823 $14,013 $127,364

Revised Inventory 11,290 942,344 $56,141 $17,145 $10,941 $84,228

Change -9,420 (764,890) -$44,387 $4,323 -$3,072 -$43,137

* Does not include the provision of information on parent companies, NAICS codes, and whether emissions are from cogeneration.

 applies to all respondents, the number of respondents is not additive.

** Because respondents to the request for data on parent companies, NAICS codes, and whether emissions are from cogeneration 

Injection and Geologic Sequestration of Carbon Dioxide (Subparts RR and UU)*

Reason for Change in Burden (see Appendix K-3 for more details):

• Shifted the activities associated with Subpart RR two years into the future to reflect the fact that Class VI UIC permits were not issued as 

quickly as anticipated in the ICR. For example, the activities estimated for Year 1 of the current ICR (2011) have been shifted to Year 1 of the

renewal ICR (2013, the first year in which Class VI injection is expected to begin). 

• Adjusted the labor hours, labor cost, O&M costs, and capital cost per facility for Subpart UU to recognize the completion of the one-time 

activities that occurred in the first year of data collection (2011).

• Adjusted the number of respondents for Subpart UU to reflect the slightly higher number of facilities anticipated in the out-years of the

previous ICR. 

Provision of Information on Parent Companies, NAICS Codes, and Whether Emissions are from Cogeneration, Not Including Mobile Sources

Reason for Change in Burden (see Appendix L-2 for more details):

• Adjusted the number of respondents to reflect available information on the actual number of facilities that reported to eGGRT (in the case

of the “Track 1” sectors) and to reflect the number of respondents estimated for the “Track 2” sectors. 

• Adjusted the labor hours and labor cost facility to recognize the completion of the one-time activities that occurred in the first year of data

collection (2010 and 2011).

All Subparts, All Activities**

Mobile Sources

Reason for Change in Burden (see Appendix M-3 for more details):

• Removed heavy-duty engine manufacturers, in which are accounted for in other ICRs (OMB No. 2060-0104, ICR No. 0783.58 and OMB No.

2060-0678, ICR No. 2394.02) 

• Corrected an error in the 2010 ICR, which capital costs were expressed as burden.
ICR for the GHGRP, DRAFT Page 30 May 2012

6(g) Burden Statement

The respondent reporting burden for this collection of information is estimated to average 

942,344 hours per year for a three-year period. The average annual burden to EPA for this period

is estimated to be 52,000 hours for oversight activities and 6,570 hours for federal facilities that 

must comply with the rule. The annual public reporting and recordkeeping burden for this 

collection of information is estimated to average 1.96 hours per response.

Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a federal agency. This 

includes the time needed to review instructions; develop, acquire, install, and utilize technology

and systems for the purposes of collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to respond 

to a collection of information; search data sources; complete and review the collection of 

information; and transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB control number. The OMB 

control numbers for EPA’s regulations are listed in 40 CFR Part 9.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OAR-2012-0333, which is available for online viewing at 

http://www.regulations.gov, or in person viewing at the Air and Radiation docket in the EPA 

Docket Center (EPA/DC), EPA West Building, Room 3334, 1301 Constitution Avenue, NW, 

Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 

p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading 

Room is (202) 566-1744, and the telephone number for the Air and Radiation docket is (202) 

566-1742. An electronic version of the public docket is available at http://www.regulations.gov. 

This site can be used to submit or view public comments, access the index listing of the contents 

of the public docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the Docket ID Number identified 

above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office 

of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk 

Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OAR-2012-0333 and 

OMB Control Number 2060-0629 on any correspondence.