2011 Technical Corrections, Clarifying and Other Amendments to the Mandatory 

Reporting of Greenhouse Gases Rule:

Subparts A, W, FF, II, OO, RR and TT Economic Impacts Memo

May 13, 2011

The 2009 final GHG reporting rule (2009 final rule) was signed by EPA Administrator Lisa 

Jackson on September 22, 2009 and published in the Federal Register on October 30, 2009 (74 

FR 56260, October 30, 2009). The 2009 final rule, which became effective on December 29, 

2009, included reporting of GHGs from various facilities and suppliers, consistent with the 2008 

Consolidated Appropriations Act. 

Subsequent notices were published in 2010 finalizing the requirements for subparts FF, II, and 

TT (75 FR 39736, July 12, 2010), subpart W (75 FR 74458, November 20, 2010), and subpart 

RR (75 FR 75060, December 1, 2010). Subpart OO, which was promulgated as part of the 2009 

final rule was also revised in 2010 (75 FR 79092, December 17, 2010). The source categories in 

40 CFR part 98 cover approximately 85-90 percent of U.S. GHG emissions through reporting by

direct emitters, as well as suppliers of certain products that would result in GHG emission when 

released, used, or oxidized, and those that geologically sequester or otherwise inject CO2 

underground. 

EPA is proposing to amend specific provisions in 40 CFR part 98, subparts A, W, FF, II, OO, 

RR and TT to correct certain technical and editorial errors that have been identified since 

promulgation and to clarify or propose amendments to certain provisions that have been the 

subject of questions from reporting entities. These proposed changes include additional 

information to clarify compliance obligations, correct data reporting elements so they more 

closely conform to the information used to perform emission calculations, and make other 

corrections and amendments.

After review of the technical corrections and consultation with technical experts who developed 

the original cost and economic analysis, EPA has determined that the proposed rule amendments 

will not impose any new requirements that are not currently required by the rules promulgated on 

October 30, 2009 (i.e., calculating and reporting annual GHG emissions) or alter the cost 
2

estimates contained in the original analyses. As a result, the original national cost estimates 

remain $208.7 million in the First Year and $119.9 million in subsequent years.

Table 1. Summary of Cost Changes Associated with the Proposed Notice of 

Reconsideration (million, 2006$)

Rulemaking

First Year

Cost 

Estimate

Subsequent 

Year Cost 

Estimate

Mandatory Reporting Rule National Cost 

Estimate (Private and Public) $132.0 $89.1

Revisons to certain provisions of the 

Mandatory Reporting of Greenhouse Gases 

(GHG) Rule

 Review of revisions $2.5 $0.0

 Subpart NN Change -$3.6 -$2.5

 Subpart C Change -$1.7 -$1.0

Reporting of Corporate Parent, NAICS Code, 

and Co-Generation Information $0.9 $0.5

Subpart W $62.9 $20.1

Subpart T, FF, II, TT $7.0 $5.5

F-Gas: Subparts I, L,DD, QQ, SS $7.6 $7.2

Subparts RR and UU: $1.1 $1.0

Total National Cost Estimate (All Final Rules) $208.7 $119.9

Proposed Technical Corrections (This 

Action) $0.0 $0.0

Revised National Cost Estimate $208.7 $119.9