## SUPPORTING STATEMENT PART A **: INFORMATION COLLECTION REQUEST** 

**FOR THE GREENHOUSE GAS**  **REPORTING PROGRAM**

**OMB Control No. 2060**  **- 0629**  **EPA ICR No. 23**  **0 0.10** 

**DRAFT**

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

### SUPPORTING STATEMENT **FOR THE GREENHOUSE GAS REPORTING PROGR**  **AM 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

- 062 9 **1(b) Short Characterization/Abstract** In response to the FY2008 Consolidated Appropriations Act (H.R. 2764; Public L aw 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 gas es ( GHGs ) from certain facilities and suppliers

. It does not require c ontrol of greenhouse gases. Instead, it requires that sources emitting above certain threshold levels of carbon dioxide ( CO 2 

### ) equivalent ( CO 2 

### e) monitor and report emissions. Subsequent rules provide corrections and clarification on existing requirements ( e.g., modif y reporting deadlines, amend calculation methodologies and data reporting requirements, clarif y rule provisions and compliance obligations, and correc t technical and editorial errors); include requirements for additional facilities suppliers, an d mobile sources ; require reporters to provide information about parent companies, N orth American Industry Classification System (NAICS ) code(s), and whether emissions are from cogeneration; and finalize confidentiality determinations

. The Office of Man agement and Budget’s (OMB’s) approval of the Information Collection Request (I CR) for the GHG Reporting Rule expires on November 30, 2012. The purpose for this ICR is to renew and revise the GHG Reporting Rul e ICR to update and combine the burdens and cost s imposed by all of the current I CRs under the GHGRP

. Appendix A summarizes the I CRs 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 IC R s associ ated with the GHGRP currently approved by OMB. This decrease reflects the completion of one - time activities that occurred in the firs t ye ar of data collection and a reduction in the number of respondents. This change is the result of a program adjustment

.ICR for the GHGRP, DRAFT Page 2 May 2012



### 2. **NEED FOR AND USE OF THE COLLECTION 2(a) Need/Authority for the Collection**  Signed into law o n December 26, 2007, the FY200 8 Consolidated Appropriations A ct (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 fr equently 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 th e 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 reasonabl y require. The CAA also provides EPA with authority in other provisions . C AA 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

- regul atory 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 quali ty 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

.ICR for the GHGRP, DRAFT Page 3 May 2012



### 2(b) Practical Utility/Users of the Data The GHGRP collects information from facilities that directl y emit GHGs and from suppliers of pro ducts that release GHGs if combusted, oxidized, or used. The comprehensive GHG data reported directly from large facilities and suppliers across the country are now easil y 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 anal yz ed. EPA’s online data publication tool allows users to view and sort GHG data for calendar ye ar 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 pow erful data resource provide s a critical tool for communities to identify nearb y 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. B usinesses and other innovators can use the data to determin e their GHG footprints, find cost

- an d 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 underst anding 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 emis sion trends from industries, within industries , and across industries over time, particularly in response to policies and potential regulations. In formation collected from the oil and gas facilities (in subpart W) and CO 2 

### injection faciliti es (in subparts RR and UU) allow s EPA to gain a better underst anding of the entire CO 2 

### capture and sequestration (CCS) system
. In formation 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

. Inaddition, historical reports in tons of chemical can be converted into CO 2 

### e , provided GWPs have been identified for these compounds

. Without this comprehensive reporting requirement, such histo rical information could be lost

. The GHGRP is not intended to be a survey and the respondents affected b y 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 GH GRP to characterize non

- reporting entities or to draw statistical inferences about a larger population.ICR for the GHGRP, DRAFT Page 4 May 2012



### 3. **NONDUPLICATION, CONSULTATIONS, A ND OTHER CO**  **LLECTION 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 an d 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 org anizations, such as the World Resources Institute/World Business Council for Sustainable Development; and

 Programs from industrial trade organizations, such a s the Interstate Natural Gas Association of America ’s GHG Emission Estimation Guidelines , the Am erican 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 CO 2 

### Accounting and Reporting Standard for the Cement Indus try
. These are important programs that not only led the way

in reporting of GHG emissions before the federal government acted but also assist ed in quantifying the GHG reductions achieved b y various policies

. Many of these programs collect different or a dditional 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 supplement s and complement s , rather than duplicate s , existing programs’ data. Further, EPA has made significant efforts over the past 4 ye ars 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 b y 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. D ocument ation of EPA’s review of GHG monitoring protocols used by federal and state voluntary and mandatory GHG programs a s well as GHG reporting rules can be found in theICR for the GHGRP, DRAFT Page 5 May 2012



### 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

- 005 2 ) , and the January 27, 200 9 memorandum entitled Review of Existing State Greenhouse Gas Reporting Rules (which can be found in the docket at EPA

- HQ

- OAR

- 2008

- 05 08

- 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 help s EPA learn more about emissions from facilities not included in current programs.

 EPA considered CO 2 

### data currently collected under Section 821 of the 1990 CAA Amendments. To avoid duplication and becaus e the Acid Rain program already requires reporting of high quality CO 2 

### data from electrical generating units (EGUs), the GHGRP allows for use of the same CO 2 

### data rather than requiring additional reporting of CO 2 

### from EGUs. Facility operators do, however, have to report the emissions of GHGs that are not included under Section 821, such as methane ( CH 4 

### ) and nitrous oxide (N 2 

### O )

.

 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 survey s (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 botto m - up approach to data collection in the GHGRP can help reduce uncertainty in emissions estimates for specific industries, and more broadl y, help s EPA transition to use of the 2006 Intergovernmental Panel on Climate Change (IPCC) Guidelines for National Gre enhouse 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 UI C permit requirements. Requirements under the UIC program are focused on demonstrating that underground sources of drinking water are not endangered as a result of CO 2 

### injection into the subsurface, while requirements under the GHGRP through subpart RR enable reporters to quantify the amount of CO 2 

### that is geologicall y 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.ICR for the GHGRP, DRAFT Page 6 May 2012



###  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 CO 2 

### sequestered in the fiscal ye ar using a mass

- balance e quation, and report to IRS the amount of qualified CO 2 

### 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 . Th e IRS reporting requirement expire s afte r 75 million metric tons of CO 2 

### is reported as sequestered to IR S , 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 CO 2 

### leakage that may occur a s is necessary

for th e rule. Therefore, EPA has concluded that the IR S data would not meet the needs outlined in the GHGRP

. As noted in the I CR for the 2009 GHG Reporting Rule , a number of programs at the state, trib al, t erritorial , and l ocal 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 emission s data with the exception of any confidential business information ( CBI) with re levant 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 I CRs, 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 receive d only a couple of comments that specifically addressed the proposed I CR s, 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 I CRs 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 1 14 and I CR requirements under the Paperwork Reduction Act, 44 U.S.C. 3501, et seq.ICR for the GHGRP, DRAFT Page 7 May 2012



### 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 inform ation has “practical utility .” EPA explained that S ection 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 IC R for a 60

- day period before it was submitted to OMB. Specificall y, EPA published a notice in the Fed eral Register (FR) requesting comment on the estimated respondent burden and other aspects of this I CR (XX FR XXXXX, see Appendix X ). An additional FR notice will be published prior to submission of this GHGRP IC R to OMB. The public comment period for this additional notice is 30 day s. **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

wo rkgroup s 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 develop ed the electronic data reporting system. The Climate Change Division within the Office o f Atmospheric Programs coordinated the eight workgroups. Prior to developing the proposed 2009 rule, e ach 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 Sy stem, the Australian GHG Reporting S ys tem, and the Canadian Mandatory Greenhouse Gas Reporting Program. In reviewing these programs, EPA anal yz ed the sectors covered, reporting thresholds, monitoring or emission s estimating methods used, quality assur anc e 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;ICR for the GHGRP, DRAFT Page 8 May 2012



###  State, local, and trib al environmental control agencies and regional air quality planning organizati ons;

 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 al so 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 hearin gs, 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 co rrection s 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 way s based o n public comments and stakeholder feedback, e.g., promulgated rulemakings that re

-propose certain subparts, add ed requirements for new facilities and supplier s, and added reporting requirements that provide information about parent companies

. Each action has had separate IC Rs at noted in Appendix A

. **3 (d)**  **Effects of Less F requent Collection**  The reporting frequency for emissions data to EPA ha s 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 A gency ’s objectives

. The GHGRP require s 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

NAI CS 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 onlyICR for the GHGRP, DRAFT Page 9 May 2012



### requiring these data elements annually , thus lessening the burden as much as possible while still gathering necessary information. EPA n eeds the data quickly at the beginning of e very reporting ye ar in order to electronically

verify it, publish it as authorized by the C AA, 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 s ys tem 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 require s 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 regul ations implementing th e Paperwork Reduction Act

. This is because facilities or suppliers that have emissions or products with emission s less than 25,000 metric tons CO 2 

### e/year for five ye ars in a row or less than 1 5,000 metric tons CO 2 

### e/year for three years in a row may cease reporting. Those that cease reporting must h ave records to cover those consecutive ye ars of emissions and must retain such records for three years following the ye ar that reporting was discontinued

. EPA selected these two time frames an d 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 ye ar to the next. EPA believes the additional three ye ar s 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 C AA and EPA regulations

. EPA ty picall y makes confidentiality

determinations under the CAA on a cas e - 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 oth er 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 protect s CBI in accordance with regulations in 40 CFR Chapter 1, P art 2, S ubpart 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 )

. The se confidentiality determinations conclude which data reporting element s 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 element s into data categories and generall y made confidentiality determinations on a category basis f or 34 source categories

. These 34 source categories represent all reporting year 2010 source categories and four reportingICR for the GHGRP, DRAFT Page 10 May 2012



### ye ar 2011 source categories (Subparts T , FF, II and TT). Additionally , EPA finalized co nfidential 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 infor mation 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 emiss ions to EPA to comply with the rulemaking. To facilitate the anal ys is, 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 CO 2 

### e threshold for the industry sectors listed below or tho se in the categories in which all must report, such as petroleum refining facilitie s and all other l arge emitters listed in Table A

- 3 of 40 CFR 98. 2(a)(1)

. Additionally , the GHGRP also require s reporting of certain emissions information associated with mob ile 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 NAI CS code for reference.ICR for the GHGRP, DRAFT Page 11 May 2012

**Part and Subpart**  **NAICS code(s)** Parts 86 , 87, 89, 90, 94 , 1033, 1039, 1042, 1045, 1048, 1051, 1054 , 1064, 1065 481 Air t ransportation ; 482 Rail t ransportation ; 483 Water t ransportation

**Part 98** C. General Stationary Fuel Combustion Sources Facilities operating boilers, process heaters, incinera tors, 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 pro ducts; 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 Ac id 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 Ce ment 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 manufactu ring 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 Product ion 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 manufact uring 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 Produ ction 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 facilitiesICR for the GHGRP, DRAFT Page 12 May 2012

**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
. Petrole um 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 Ethy lene 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 fa cilities 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 Diox ide Production 325188 Titanium dioxide manufacturing facilities FF. Underground Coal Mines 212113 Underground an thracite coal mining operations; 212112 Underground bituminous coal mining operations GG
. Zinc Production 331419 Primary zinc refining facilit ies; 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 facili ties ; 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 t he expenditure of funds for this purpose. LL. Suppliers of Coal

based Liquid Fuels 211111 Coal liquefaction at mine sites MM. Suppliers of Petroleum Products 324110 Petroleum refineriesICR for the GHGRP, DRAFT Page 13 May 2012

**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 manufact uring facilities QQ. Importers and Exporters of Pre

- charged Equipment and Closed

Cell Foams 423730 Air
- conditioning equipment (except room units) merchant wholesalers ; 333415 Air
- conditioning equipment (except motor vehicle) manufacturing ; 336391 Motor ve hicle air
conditioning manufacturing; 423620 Air
- conditioners, room, merchant wholesalers ; 443111 Household Appliance Stores ; 423730 Automotive air
- co nditioners 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 CO 2 enhanced oil and gas recovery; 211111 or 211112 Projects that inject acid gas containing CO 2 und erground; N/A CO 2 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 w aste 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 ; 22 1320 Sewage treatment facilities UU. I njection of Carbon Dioxide 211 Oil and gas extraction projects using CO 2 enhanced oil and gas recovery; 211111 or 211112 Projects that inject acid gas containing CO 2 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 Reques **ted** (i ) Data Items Re porting RequirementsICR 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 CO 2 

### e/ye ar report GHG emissions data to EPA annuall y. Specificall y, 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 CO 2 

### e/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 CO 2 

### e/year in combined emissions from stati onary 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 CO 2 

### e/year are onl y required to report emissions from combustion sources. Respondents comply

with the following categories of requirements (if applicable): th e G eneral 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 part s 86, 87, 89, 90, 94, 103 3, 1039, 1042, 1045, 1048, 1051, 1054, and 1065 report CO 2 

### , N 2 

### O, and CH 4 

### emissions associated with the mobile sources that they produce. The f ollowing is a summary

of the information requested by source category ; requirements that apply to specific source s 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 respondent s report submit the following information electronicall y: 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 su

bmittal; 4. For facilities, except as otherwise provided in 40 CFR 98.3 (c)(12) , annual emissions of CO 2 

### , CH 4 

### , N2 

### O, and each fluorinated GHG (as defined in 40 CFR 98. 6) as follows: a. Annual emissions (excluding biogenic CO 2 

### ) aggregated for all GHG from all appli cable source categories and expressed in metric tons of CO 2 

### e calculated using Equation A

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

### b. Annual emissions of biogenic CO 2 

### aggregated for all applicable source categories, expressed in metric tons ; c. Annual emissions from each applica ble s ource category , expressed in metric tons of each GHG listed as follows: i) Biogenic CO 2 

### ; ii) CO 2 

### (excluding biogenic CO 2 

### ); iii) CH 4 

### ; iv); N2 

### O; and v) Each fluorinated GHG (including tho se 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” sec tion of each applicable subpart. e. Emissions and other data for individual units, processes, activ ities, 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 CO 2 

### e for onl y 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 el ements specified in Table A

–7 of subpart A for calendar ye ars 2010 through 2013 until March 31, 2015. 5. For suppliers, annual quantities of CO 2 

### , CH4 

### , N 2 

### O, 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 aggregat ed for all GHG from all applicable supply categories in Table A

– 5 of subpart A and expressed in metric tons of CO 2 

### e calculated using Equation A

– 1 of subpart A . For fluorinated GHGs, calculate and report CO 2 

### e for onl y 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 parameter s 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. NAI CS 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 NAI CS code(s). Report all additional NAI CS 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 phys ical 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

o r supplier is entirely

owned by

a single United States company that is not owned by another company, provide that company's legal name and phys ical 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, its elf, owned b y 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 leg al names and phy sical 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 phy sical address of the joint venture or cooperative as the United States parent company, and report 100 percent ownership b y the joint venture or cooperative. e. If the facility

or supplier is entirely

owned by

a foreign company, provide the legal name and phys ical 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 phys ical address o r percent ownership. Under 40 CFR 98.3(h), the owner or operator submit s a revised rep o rt within 45 day s 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 submit s the certificate of representation at least 60 day s before the report deadline

. Under 40 CFR 98.4(i ), the certificate of representation include s : 1. An identification of the facility or supplier for which the certificate of representation is s ubmitted; 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 s upplier 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 submit s electronically to the Administrator a notice of delegati on 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 design ated 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 ty pe or ty pes 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 CF R 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 **m ay**  **d iscontinue**  **r eporting**  **.** Under 98.2(i), i f reported emissions are less than 25,000 metric tons CO 2 

### e/year for five consecutive years or less than 15,000 metric tons CO2e/ye ar for three consecutive ye ars , 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 maintain s the corresponding records required under 40 CFR 98.3(g) for the five (or three) consecutive ye ars and then retain such records for three years following the ye ar 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 th e 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, in dustrial waste landfills, or underground coal mines. The owner or operator resume s reporting for any future calendar year during whic h any of the GHG

- emitting processes or operations resume operation. **Other source categories.** F acilities that contain any of the source categories listed in S ection 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 facilitie s that are affected b y 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 ye ars 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 readil y available for expeditious inspection and review. For records that are electronicall y 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) Anal ytical results for the development of site

spe cific emissions factors; (iii) The results of all required analy ses 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 in clude, at a minimum, the following: (i) Id entification 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 (i ii) 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 th e 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 sy stems to reduce the frequency of moni toring equipment downtime. b. Upon request b y 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 s ys tems, flow meters, and other instrumentation used to provide data fo r the GHGs reported under 40 CFR 98.ICR for the GHGRP, DRAFT Page 20 May 2012



### Other source categories. Facilities that repo rt 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 th e GHGRP ’s reporting requirements report s total annual GHG emissions in metric tons of CO 2 

### e , as applicable

. The primary tasks that reporting program respondents perform include : 1. Implement and update, as necessary , appropriate monitoring plan s 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 ye ars. 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 generall y 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**  **ME THOD**  **S , 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 Me thodology and Management**  EPA has establish ed a central repository of inventory

data for all respondents , the web

based Electronic Greenhouse Gas Reporting Tool (e

- GGRT). Respondents report data electronically , and EPA store s the data in the database. Faci lities and suppliers subject to the GHGRP register online through th e e - GGRT sy stem. All data is submitted to EPA electronicall y in e

- GGRT except the one

- time Electronic Signature Agreement (ESA) which is submitted on paper. The tool has an XMLreportingICR for the GHGRP, DRAFT Page 21 May 2012



### schema that allow s facilities to upload GHG data directly in lieu of using the web fo rms provided through e

- GGRT. The XMLreporting 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 s ys tems to which electronic submissions must be made and the requirements for valid electronic signatures. Additionally , E
- GGRT can handle CBI. The new s ys tem follow s Agency standards for design, security , data element and reporting format conformance, and accessibility . EPA designed the database in an attempt to minimize respondents’ burden b y 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 D R , 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 PI N or password) is required to submit a report. **5(c) Sm**  **all Entity Flexibility** EPA took several steps to minimize the impac ts 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 use s existing GHG emission s estimation and reporting methodologies and provide s simplified methodological options to reduce reporting burden. According to the Agency’s anal ys is, 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 ty pe of fossil fuel , would not exceed 25,000 metric tons CO 2 

### e/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 minimize d the impact on small entities in subpart NN ( Suppliers of Natural Gas and Natural Gas Liquids ) b y 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 ye ar 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 CO 2 

### e/year for 5 year s 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

. M ost fac ilities 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) annuall y. 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 become s subject to the GHGRP because of a physical or operational change report emissions for the first calendar ye ar in which the change occurs beginning with the first month of the change

. A f acility or supplier that become s subject to the GHGRP solely

because of an increase in hours of operation or level of production report s 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 ye ar . F acilities or suppliers that have emissions or products with emission less than 25,000 metric tons of CO 2 

### e for five ye ars in a row or less than 15,000 metric tons of CO 2 

### e for three ye ars 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 fo r the reduction in emissions. The notification must be submitted no later than March 31 of the year immediately

following the fifth (or third) consecutive ye ar of emissions less than 25,000 (or 15,000) tons CO 2 

### e/year. The owner or operator must maintain th e corresponding records required under 40 CFR 98 .3(g) for each of the five (or three) consecutive years and retain such records for three ye ars following the year that reporting was discontinued. The owner or operator must resume reporting if annual emissi ons in any future calendar year increase to 25,000 (or 15,000 ) metric tons CO 2 

### e/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 activitie s 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 wi ll average 900 thousand hours per ye ar 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 ty pes. 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 ye ar 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 ye ar; for facilities collecting samples on a dail y basis, this mean s a minimum of 365 responses per year. Exhibit 6.1 presents aggregate burden by sector onl y; for the details of burden calculations, please see the cost appendices

. **6(b) Estimating Respo**  **ndent 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 non

labor 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 sec tors 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 ye ars covered b y this information collection. Exhibit 6.1 presents aggregate costs b y sector only; for the details of EPA’s cost cal culations, please see Appendix C

.

[1] May 2011 National Industry

- Specific Occupational Employment and Wage Estimates (http://www.b ls.gov/oes/current/oessrci.htm) and Em ployer 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 F**  **or the GHG Reporting Program**  **($K)**

**So urc**  **e Cate**  **gory No.**  **Re sponde**  **nts Re**  **spons es**  **/ Re**  **sp onde**  **nt To**  **ta l** 

**Re spons** **es To**  **ta l** 

**Burden (h**  **rs) To**  **ta l**  **La bor** 

**Cost ($**  **K) Capital** 

**Cos t**  **($ K)**  **O& M**  **Cos**

**t ($**  **K) Tot**  **al C**  **ost**

**($ K)** 
C. St ationaryCo mbustion (ge nera l unspecified) 2,568 40 102,184 258,675 $15,304 $820 $2,366 $18,490 D. El ectricityGe nera tion 1,259 9 9,815 68,171 $4,035 $0 $0 $4,035 E. Ad ipic Ac id Prod. 3 28 84 555 $33 $0 $25 $58 F. Al umi num Production 12 17 198 3,604 $232 $0 $3 $235 G. Am monia Ma nuf

ac turing 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. El ectronics Ma nuf

acturing 94 7 662 35,001 $2,055 $3,512 $0 $5,567 K. Fe rroa lloyP roduction 10 99 987 821 $48 $0 $16 $65 L. Fl uori na ted Greenhouse Ga s Prod 14 7 99 2,601 $142 $33 $14 $190 N. G lass Production 106 102 10,816 8,506 $508 $0 $107 $615 O. H CFC- 22 Production an d HFC23 Destruction 5 92 460 768 $42 $0 $0 $42 P. Hydrogen Production 46 23 1,057 3,428 $203 $0 $87 $290 Q. I ron an d St eel Production 122 92 11,229 35,158 $1,848 $0 $275 $2,123 R. Lead P roduction 12 102 1,224 1,053 $62 $0 $19 $81 S. Lime Ma nuf

ac turing 70 544 38,083 15,312 $909 $422 $1,109 $2,439 T. Ma gnes ium Production 11 9 99 2,061 $123 $0 $2 $124 U. Mi sc . Us es of

C ar bona te 0 0 0 0 $0.00 $0.00 $0.00 $0.00 V. Ni tric Ac id P roduction 37 42 1,557 6,728 $421 $14 $177 $613 W. Oi l an d Na tura l Ga s Sys tems 2,786 8 21,201 229,624 $14,215 $730 $1,687 $16,631 X. Pe trochemical Prod. 63 92 5,799 12,807 $737 $0 $582 $1,319 Y. P etroleum Re fi neries 146 92 13,438 57,512 $3,332 $173 $224 $3,728 Z. Phos phoric Ac id P rod 10 544 5,440 2,187 $130 $60 $158 $348 AA. P ulp & Pa pe r Mn fc trng 116 92 10,677 11,148 $655 $1,709 $43 $2,407 BB. Silicon Ca rbide Production 1 37 37 153 $9 $0 $0 $9 CC. Soda As h Ma nuf

ac turing 4 93 372 932 $57 $0 $7 $64 DD. Su lf ur He xa fl uori de (SF6 ) from El ectric Power Sys tems 141 7 993 10,635 $596 $0 $0 $596 EE. Ti tanium Dioxide Production 7 93 651 1,091 $65 $0 $3 $68 FF. Unde rg round Coa l Mi nes 114 21 2,366 4,702 $274 $220 $456 $950 GG. Zi nc Production 6 108 648 657 $39 $1 $5 $45 HH. La ndfills 1,195 92 109,989 45,311 $2,611 $66 $127 $2,804 II. Wa stewa ter 358 7 2,525 3,203 $188 $284 $1,017 $1,489 JJ. Ma nure Ma na ge ment (3 ) 107 91 9,801 4,643 $275 $1 $0 $276 LL. Suppliers of Coa l- ba sed Liquid Fue ls, MM. S uppliers of Petrol. Prod. 315 99 31,057 13,375 $936 $0 $0 $936 NN. Suppl ies of Na t Ga s an d Na t Ga s Liquids 474 53 25,240 31,095 $1,852 $0 $0 $1,852 OO. Su ppl ier s of

I ndustrial GHG 49 15 737 2,733 $163 $0 $0 $163 PP. Suppliers o f C O2 130 36 4,685 5,882 $346 $0 $0 $346 QQ - I mports an d Ex ports o f Fluori na ted GHGs i n Products 158 7 1,112 11,063 $661 $0 $0 $661 RR. Ge olog ic Se que str ation of Ca rbon Di oxide 3 23 61 2,139 $125 $135 $327 $587 SS - S F6 Eq uipment Producers 10 7 70 441 $24 $0 $0 $24 TT -I ndustrial La ndfills 200 8 1,608 13,493 $782 $11 $88 $881 UU. Inje ction of

C ar bon Dioxide 92 12 1,110 4,150 $241 $0 $208 $450 Mo bile So urces 316 1 316 626 $36 $8,407 $0 $8,442 **TOTA L**  11,039 Va ries 480,851 942,344 $56,141 $17,145 $10,941 $84,228 (2) EP A is in t he pro ce ss of reviewing t he num ber ofres po ns es p er respo ndent t o ens ure co ns is tenc y i n ho w bu rden is ch arac terized am on g subparts

. Th is a naly

si s wi ll no t affe ct th e tota l burden per su bpart

. (1) So me respo ndent s belo ng to m ult iple sou rc e c atego ries , s o the num ber o f respo ndent s is n ot a ddit iv e.
(3) EP A wi ll no t be imp lem ent ing SubpartJ J due t o a C on gres si on al res tr icti on p ro hibit ing t he expendit ure off unds for t his p urpo se.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 pro gram and required reporting b y federal l y owned GHG generating facilities. EPA Burden and C

ost 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 hourl y 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 ye ars of the information collection for developing guidance, training, responding to stakeholders, communication and outreach , database maintenance, and other contractor support. B urden and cost for federal facilities covered by the rule F ederal ly owned facilities that exceed the CO 2 

### e threshold must report their GHG emissions

. In2010, federally owned facilities reported in Subparts C (Stationary Combustion, general unspecified) , D (E lectricity Generation), V (Nitric Acid Production), and HH (L andfills ). It is anticipated that federally owned facilities will also report under Subparts RR and UU ( S equestration of CO 2 

### , under which federally o wned facilities are anticipated to seek exemptions, and Injection of CO 2 

### ). 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 facili ties 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** 

**Inf orm**  **at ion C**  **olle cti**  **on Acti**  **vi ty**  **Annua l**  **Re sp**  **ons**

**es Tot** **al An**  **nua l**  **Bu rde**  **n La**  **bor Co**  **st Non-**  **La bor**  **Co st**  **Tot al**  **A nnua**  **l**

**Co st** 
Gui danc e Dev

el opm ent , Training, Au di ts, a nd General O ve rs ig ht 1 52, 000 2 ,7 23, 240 1 0, 666, 667 $13, 389, 907
C. Sta ti onary C om bus tio n (general uns pec if

ied) 1950 4, 936 $292, 012 $60, 792 $352, 804 D. Ele ctricity G enerat ion 148 1, 029 $60, 887 $0 $60, 887 V. N itric Aci d Pr

oduc tio n 42 182 $11, 382 $5, 174 $16, 555 HH. L andf

ills 92 228 $13, 112 $965 $14, 077 RR. G eol ogic Se ques trat io n of Carbon Diox ide 1 16 $930 0 $930 UU. I nj ec tio n of CO2 4 180 $10, 461 $9, 024 $19, 485 **TOTA L**  **2 ,2**  **38 5**  **8, 570**  **3 ,1**  **12, 025**  **1 0,**  **742, 621**  **1 3,**  **854, 646**  **Bu rde**  **n for**  **Com plia**  **nc e**  **by F**  **ed er** **al F ac**  **ilit ies**  **Ove rs** **ig ht** 



### 6(d) Estimating the Responden **t 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 I CR

. **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** 

Nu mb er of Re sp onde nt s 11, 290 Fr om E xh ib it6. 1
Tota l An nua l Res pons es 4 80, 851 Fr om E xh ib it6. 1

43 = 4 80, 851 To ta l an nua l re sp ons es from a bove **÷**

1 1, 290 To ta l re sp onde nt s from a bove Tota l Re sp onde ntHour s 9 42, 344 Fr om E xh ib it6. 1
Hour s pe r Re sp ons e 1. 96 = 9 42, 344 To ta l an nua l hour s fr om a bove **÷** 4 80, 851 To ta l re sp ons es fr oma bove An nua l O&M a nd Ca pi ta l Cos t $28, 086, 090 Fr om E xh ib it6. 1
Tota l Re sp onde ntCos t (l ab or +non) $84, 227, 545 Fr om E xh ib it6. 1
1 ,0 00, 914 = 9 42, 344 To ta l re sp onde nthour s from a bove **+** 5 8, 570 To ta l EP A hours fr omE xhi bi t 6- 2 9 8, 082, 191 = $ 84, 227, 545 To ta l re sp onde ntc os t fr oma bove **+**

$ 13, 854, 646 To ta l EP A co st fr om Ex hi bi t 6- 2 Nu mb er of Re sp ons es pe r Re sp onde nt

Tota l Hour s (Re sp onde nt s an d A ge ncy)
Tota l Cos t (Re sp onde nt s an d Agen cy ) 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 I CR s .ICR for the GHGRP, DRAFT Page 28 May 2012 

### Exhibit **6.4 Summary of Changes in Annual Burden** 

**Tit le**  **Current**

**OMB Cont ro**  **l Nu**  **mber Re**  **fe renc** **e**

**EP A I**  **CR Nu**  **mb er(**  **s) No.** 

**Re sponde**  **nt s**  **Tot al Bur**  **de n** 

**(hrs) To**  **ta l L**  **ab or** 

**Cost ($**  **K) Ca**  **pit al Cost** 

**($ K)**  **O&M Cost**

**($K) To**  **ta l Cost** 

**($ K)** 

Cur re ntI nve nt ory 2060- 0629 2300. 03 - 2300. 09 16, 408 1, 024, 285 $54, 994 $8, 770 $10, 314 $74, 079 Revi se d I nve nt ory 6, 742 618, 043 $36, 381 $3, 813 $7, 142 $47, 335 Cha nge -9, 666 (406, 242) -$ 18, 614 -$4, 957 -$3, 173 -$26, 743

Cur re ntI nve nt ory 2060- 0647 2396. 01, 2396. 02 683 65,9 58 $3, 635 $515 $1, 563 $5, 713 Revi se d I nve nt ory 683 22,9 96 $1, 337 $515 $1, 563 $3, 415 Cha nge 0 (42,9 62) -$2, 298 $0 $0 -$2, 298

Cur re ntI nve nt ory 2060- 0651 2376. 02, 2376. 03, 2376. 05 2, 786 394, 757 $25, 139 $745 $1, 687 $27, 570 Revi se d I nve nt ory 2, 786 227, 738 $14, 091 $730 $1, 687 $16, 508 Cha nge 0 (167, 019) -$ 11, 048 -$ 15 $0 -$11, 063

Cur re ntI nve nt ory 2060- 0650 2373. 02 - 2373. 04 417 76,7 01 $4, 152 $2, 705 $10 $6, 866 Revi se d I nve nt ory 417 59,4 58 $3, 461 $3, 545 $14 $7, 020 Cha nge 0 (17,2 43) -$691 $841 $5 $154 **“T ra**  **ck 1” S**  **ubpa rts** **, N ot**  **I nc**  **luding Mobile Sourc** **es (Subpa**  **rts C,** **D, E, F, G, H, N ,**  **O, P,** **Q, R** **, S, U, V**  **, X, Y, Z, AA, BB, CC, EE, GG, HH, JJ, L**  **L, MM, N**  **N, OO,** **a nd PP)** 

**Mag ne**  **sium Product**  **ion, U nderg**  **round Coa l**  **Mine s, In**  **dust ri**  **al Wast ewa**  **ter T rea**  **tment, a**  **nd I ndust**  **ri al**  **Wa st**  **e La ndfills (Subpar**  **ts T**  **, FF, I**  **I, an**  **d TT)***

**Pet roleum a**  **nd Na tu**  **ra l Gas Syst**  **ems (Subpar**  **t W)** * **Re ason for**  **Cha nge**  **i n Bur**  **de n (Se**  **e Appendix G -3 for**  **more deta ils)**  • Removed one -ti me burde n for cove rag e de ter mi na ti on, whi ch a ffec ted 19, 848 re sp onde nts , who i ncurre d 258, 019 hours i n burde n (ove r th re e ye ars , thi s av er ag ed 6 ,6 10 re sp onde nt s an d 8 6, 006 hours ). • Ad ju st ed thenumbe r of re sp onde nt s ba se d on t henum be r of fa ci lit ie s th atre por ted t o e GGRT. • Ad ju st ed thel ab or hours , l ab or c os t, O &M c os ts , a nd ca pi ta l cos t pe r fa cility t o re cog ni zet hec om pl eti on of t heone -ti me act iv it ie s th at occurre d i n t hefi rs t ye ar of da ta c ol le ct io n (2010).

**Re ason for**  **Cha nge**  **i n Bur**  **de n (se**  **e Appendix H-3 for more deta**  **ils)** • Ad ju st ed thel ab or hours a nd l ab or cos t pe r fa ci lity t o re co gni ze th e com pl eti on of t heone -ti me ac ti vi ti es t ha t oc curre d i n t hefi rstye ar of da ta c ol le ct io n (20 11).

**Re ason for**  **Cha nge**  **i n Bur**  **de n (se**  **e Appendix I -3 for more de**  **ta ils):**  • Ad ju st ed thel ab or hours , l ab or c os t, a nd O&M cos t pe r fa ci lity t o re cog ni ze the c om pl eti on of t heone -ti me act iv it ie s th atoccurre d i n t he fi rs t ye ar of da ta c ol le ct io n (2011). • Corre ct ed a n e rror i n t he2010 I CR, i n w hi ch t heburde n hours for two a ct iv it ie s wer e su mmed i nc orre ct ly (s ee Ap pe ndi x F-3). **Addit ional Sour**  **ce s**  **of Fluor ina**  **ted GHG (Subpar**  **ts I**  **, L,** **DD, QQ, and SS)***

**Re ason for**  **Cha nge**  **i n Bur**  **de n (se**  **e Appendix J -3 for more de**  **ta ils):**  • Ad ju st ed thel ab or hours , l ab or c os t, O &M c os ts , a nd ca pi ta l cos t pe r fa cility t o re cog ni zet hec om pl eti on of t heone -ti me act iv it ie s th at occurre d i n t hefi rs t ye ar of da ta c ol le ct io n (2011). • No te: E PA

i s cons id er in g fut urea men dm en ts t o Subpa rtI . Thes e ch an ges w oul d bedocum en ted i n a fut ur e IC R, whi ch w oul d a men d t hi s re ne wa l IC R.ICR for the GHGRP, DRAFT Page 29 May 2012 

### Exhibit **6.4 Summary of Changes in Annual Burden**  **(continued)**

**Tit le**  **Current**

**OMB Cont ro**  **l Nu**  **mber Re**  **fe renc** **e**

**EP A I**  **CR Nu**  **mb er(**  **s) No.** 

**Re sponde**  **nt s**  **Tot al Bur**  **de n** 

**(hrs) To**  **ta l L**  **ab or** 

**Cost ($**  **K) Ca**  **pit al Cost** 

**($ K)**  **O&M Cost**

**($K) To**  **ta l Cost** 

**($ K)** 

Cur re ntI nve nt ory 2060- 0649 2372. 02, 2372. 03 89 4,7 94 $357 $88 $439 $884 Revi se d I nve nt ory 93 6,2 24 $362 $135 $535 $1, 033 Cha nge 4 1,4 30 $5 $47 $96 $148

Cur re ntI nve nt ory 2060- 0646 2374. 02 10, 551 9,4 87 $571 $0 $0 $571 Revi se d I nve nt ory 10, 723 7,2 59 $475 $0 $0 $475 Cha nge 172 (2,2 28) -$97 $0 $0 -$97

Cur re ntI nve nt ory, Not In cl udi ng Be lo w 2060- 0629 2300. 03 317 140, 680 $8, 605 $0 $0 $8, 605 Cur re ntI nve nt ory, A ir craft En gi ne s 2060- 0680 2427. 02 10 60 $3, 646 $0 $0 $3, 646 Revi se d I nve nt ory 316 6 26 $36 $8, 407 $0 $8, 442 Cha nge -11 (140, 114) -$ 12, 216 $8, 407 $0 -$3, 809

Cur re ntI nve nt ory 20, 710 1, 707, 234 $100, 529 $12, 823 $14, 013 $127, 364 Revi se d I nve nt ory 11, 290 942, 344 $56, 141 $17, 145 $10, 941 $84, 228 Cha nge -9, 420 (764, 890) -$ 44, 387 $4, 323 -$3, 072 -$43, 137 * Doe s noti ncl udet heprovi sio n of i nform at io n on pa re ntc om pa ni es , NAI CS code s, a nd w heth er emi ssio ns a refr om c oge ne rat io n.
a ppl ie s to a ll re sp onde nts , the nu mb er of re sp onde nt s is nota ddi ti ve . ** Be cau sere sp onde nt s to t here que stfor da ta on pa re ntc om pa ni es , NAI CS code s, a nd w heth er e mi ssio ns a refr om c oge ne rat io n **In je**  **ct ion a**  **nd Ge ologic Se**  **ques tra**  **ti on of Ca**  **rb on Dioxide**  **(Subpa rts** **RR and U U)** *

**Re ason for**  **Cha nge**  **i n Bur**  **de n (se**  **e Appendix K-3 for more deta**  **ils):** • Shi fted t hea ct iv it ie s asso ci at ed wi th Subpa rtRR two ye ars in to t hefut uret o refl ec t th e fa ctt ha t Cl ass VI U ICpe rm it s wer e noti ssu ed a s qui ck lya s an ti ci pa ted i n t heI CR. For exam pl e, th e act iv it ie s es ti ma ted for Yea r 1 of t hec urre ntI CR (2011) ha vebee n s hi fte d t o Yea r 1 of the re ne wa l IC R (2013, t hefi rs t ye ar in whi ch Cl ass VI i nj ec ti on i s ex pe ct ed t o be gi n). • Ad ju st ed thel ab or hours , l ab or c os t, O &M c os ts , a nd ca pi ta l cos t pe r fa cility for Subpa rtU U to r ec ogni zet hec ompl eti on of t heone -ti me act iv it ie s th atoccurre d i n thefi rs t ye ar of da ta c ol le ct io n (2011). • Ad ju st ed thenumbe r of re sp onde nt s for Subpa rtUU to r ef le ctt hes lig ht ly hi ghe r num be r of fa ci lit ie s an ti ci pa ted i n t heout -ye ars of t he pre vi ous I CR. **Provision of I nfor**  **ma ti**  **on on Pa rent Compa**  **nie s, N**  **AICS Code s, and W**  **he th**  **er Em**  **issions ar e fr**  **om Cogenera ti**  **on, Not I**  **nc luding Mobile**  **Sourc es** 

**Re ason for**  **Cha nge**  **i n Bur**  **de n (se**  **e Appendix L-2 for more deta**  **ils):** • Ad ju st ed thenumbe r of re sp onde nt s to re fl ec t av ailab lei nform at io n on thea ct ua l num be r of fa cilit ie s th atre port ed t o eGGRT (i n t hec ase of the“ Tr ack1”s ec to rs ) a nd t o refl ec t th e num be r of re sp onde nt s es ti ma ted for t he“ Tr ack 2”s ec to rs . • Ad ju st ed thel ab or hours a nd l ab or cos t fa ci lity to r ec ogni ze the c om pl eti on of t heone -ti me act iv it ie s th atoccurre d i n t hefi rs t ye ar of da ta col le ct io n (2010 a nd 2011).

**All Subpa rts**  **, All Ac** **ti vit**  **ie s** ** **Mo bile**  **Sourc es** 

**Re ason for**  **Cha nge**  **i n Bur**  **de n (se**  **e Appendix M -3 for more deta**  **ils):** • Removed he av y-duty e ngi nem an ufa ct ure rs, i n w hi ch a rea ccount ed for i n ot he r I CRs (OMB N o. 2 060-0104, I CR No. 0 783. 58 a nd OMB N o. 2060- 0678, I CR N o. 2394. 02) • Corre ct ed a n e rror i n t he2010 I CR, whi ch ca pi ta l cos ts we reexpr es se d a s burde n.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 ye ar for a three

- ye ar 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 f ederal 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 re sponse. Burden means the total time, effort, or financial resources expended b y 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 sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with any previously

applicable instructions and requirements; train personnel to respond to a co llection 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 I CR under Docket ID Number EPA

- HQ

- OAR

- 2012

- 0333 , which is available for online viewing at http://www.regulations.go v, 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 holiday s. 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.regulati ons.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 sy stem, 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 th e EPA Docket ID Number EPA

- HQ

- OAR

- 2012

- 0333 and OMB Control Number 2060

- 0629 on any correspondence

.