MEMORANDUM 

Date: February 6, 2013 

From: Rachel Schmeltz, US EPA 

Subject: Summary of Evaluation of “Inputs to Emission Equations” Data Elements Proposed to be 

Added with the 2013 Revisions to the Greenhouse Gas Reporting Rule 

The purpose of the memorandum is to document EPA’s evaluation of thirteen new data elements that 

EPA is proposing to add with the 2013 Revisions to the Greenhouse Gas Reporting Rule and 

Confidentiality Determinations for New or Substantially Revised Data Elements. These 13 data elements

are being added to the following subparts of the Greenhouse Gas Reporting Rule: 

• 2 data elements to Subpart FF (Underground Coal Mines) 

• 5 data elements to Subpart HH (Municipal Solid Waste Landfills) 

• 6 data elements to Subpart TT (Industrial Waste Landfills) 

As explained in the preamble to the proposed rule, we propose to assign these 13 data elements to the

“ inputs to equations” data category. In the final deferral rule (76 FR 53057) and the accompanying 

memorandum entitled “Process for Evaluating and Potentially Amending Part 98 Inputs to Emission 

Equations” (Docket ID EPA-HQ-OAR-2010-0929), EPA described a four-step evaluation process for inputs 

to equations, which are as follows: 

• Step 1: Determine whether each input is already publicly available. 

• Step 2: For inputs that are not publicly available, evaluate whether release of the 

information is likely to result in substantial competitive harm. 

• Step 3: For inputs that are likely to cause substantial competitive harm if disclosed, evaluate 

potential alternative calculation methods. 

• Step 4: For inputs that are likely to cause substantial competitive harm if disclosed, evaluate 

potential alternative verification methods. 

A full description of the four-step evaluation process that was undertaken as well as the market 

structure for each of these subparts is described in the December 17, 2012 memo titled “Summary of 

Evaluation of Greenhouse Gas Reporting Program (GHGRP) Part 98 “Inputs to Emissions Equations” Data 

Elements Deferred until 2013”. 

As discussed in more detail in the appendix to this memorandum, EPA found that the new inputs 

described in this memo are not the types of data that would allow competitors to gain competitive 

advantage if publicly released. As a result, EPA did not proceed to Steps 3 and 4 of the four-step 

process. 

 
Appendix: 

Step 1: Public Availability Analysis: 

EPA found that none of the data elements in this analysis are publicly available. EPA searched the 

following sources: 

• Subpart FF: EPA’s Coalbed Methane Outreach Program (CMOP), Mine Safety and Health 

Administration (MSHA) 

• Subpart HH: EPA’s Landfill Methane Outreach Program (LMOP), Title V permits, Waste Business 

Journal, state web sites, company and municipal web sites 

• Subpart TT: National Emissions Inventory, LMOP database, Waste Business Journal, Title V 

permits 

Step 2: Competitive Harm Analysis 

The market structure analysis for each of these subparts is described in the December 17, 2012 memo 

titled “Summary of Evaluation of Greenhouse Gas Reporting Program (GHGRP) Part 98 “Inputs to 

Emissions Equations” Data Elements Deferred until 2013”. Based on these market structure analyses, 

EPA proceeded to evaluate individual data elements.

Table 1 below lists the proposed data elements evaluated for this action and the assessment related to

Step 2 for each data element. 

Table 1. Evaluation of Proposed New Inputs to Emission Equations 

Subpart Citation Data Element Assessment by Data Element

FF 98.326(o) The moisture correction factor (if 

applicable) used in Equation FF-1 

and FF-3 

Release of these data elements 

would not disclose any proprietary 

information, such as the amount or 

grade of coal produced, production 

efficiency, production costs, 

operating methods, or remaining 

coal reserves. 

FF 98.326(t) Quarterly CH4 routed to each 

destruction device or offsite 

transfer point 

HH 98.346(h) Oxidation fraction used in the 

calculation for methane 

generation for landfills without 

gas collection systems 

These data elements would not 

reveal any information about landfill 

fees, revenues, costs, or contracts 

and would not reveal any details 

about manufacturing processes, 

products, or raw materials. 

HH 98.346(i)(8) Oxidation fraction used in 

Equation HH-5 for landfills with 

gas collection systems 

HH 98.346(i)(10) Oxidation fraction used in 

Equation HH-7 for landfills with 

gas collection systems 

HH 98.346(i)(11) Oxidation fraction used in 

Equation HH-6 for landfills with 

gas collection systems 

HH 98.346(i)(12) Oxidation fraction used in 

Equation HH-8 for landfills with 
gas collection systems

TT 98.466(c)(5)(i) WIP at start of reporting year, or 

design capacity for closed landfills

These data elements do not provide 

any proprietary information about 

the manufacturing facility or its 

processes, raw materials, and 

production. They also do not 

provide any economic information 

about the landfill. 

TT 98.466(c)(5)(ii) The cumulative quantity of waste 

placed in the landfill 

TT 98.466(c)(5)(iii) YrLast, the last year, prior to the 

reporting year, that the landfill 

received waste 

TT 98.466(c)(5)(iv) YrOpen, Year 1960 or the year in 

which the landfill first received 

waste from company records, 

whichever is more recent 

TT 98.466(c)(5)(v) NYrData, the number of years for 

which annual waste disposal 

quantities are available from 

company records or from 

Equation TT-3 of this section from 

YrOpen to YrLast inclusive 

TT 98.466(h) For landfills with gas collection 

systems, oxidation fraction 

This data element does not reveal 

detailed information on the 

composition of waste or any 

manufacturing process or economic 

data.