Mandatory Greenhouse Gas 

Reporting Rule: EPA's Response 

to Public Comments 

Volume No.:43 

Subpart J—Ethanol Production 
June 2010 

Subpart J—Ethanol Production 

U. S. Environmental Protection Agency 

Office of Atmosphere Programs 

Climate Change Division 

Washington, D.C. 
iii

FOREWORD 

This document provides EPA’s responses to public comments on EPA’s Proposed Mandatory 

Greenhouse Gas Reporting Rule. EPA published a Notice of Proposed Rulemaking in the 

Federal Register on April 10, 2009 (74 FR 16448). EPA received comments on this proposed 

rule via mail, e-mail, facsimile, and at two public hearings held in Washington, DC and 

Sacramento, California in April 2009. Copies of all comments submitted are available at the 

EPA Docket Center Public Reading Room. Comments letters and transcripts of the public 

hearings are also available electronically through http://www.regulations.gov by searching 

Docket ID EPA-HQ-OAR-2008-0508. 

Due to the size and scope of this rulemaking, EPA prepared this document in multiple volumes, 

with each volume focusing on a different broad subject area of the rule. This volume of the 

document provides EPA’s responses to significant public comments received for 40 CFR Part 

98, Subpart J—Ethanol Production. 

Each volume provides the verbatim text of comments extracted from the original letter or public 

hearing transcript. For each comment, the name and affiliation of the commenter, the document 

control number (DCN) assigned to the comment letter, and the number of the comment excerpt is 

provided. In some cases the same comment excerpt was submitted by two or more commenters 

either by submittal of a form letter prepared by an organization or by the commenter 

incorporating by reference the comments in another comment letter. Rather than repeat these 

comment excerpts for each commenter, EPA has listed the comment excerpt only once and 

provided a list of all the commenters who submitted the same form letter or otherwise 

incorporated the comments by reference in table(s) at the end of each volume (as appropriate). 

EPA’s responses to comments are generally provided immediately following each comment 

excerpt. However, in instances where several commenters raised similar or related issues, EPA 

has grouped these comments together and provided a single response after the first comment 

excerpt in the group and referenced this response in the other comment excerpts. In some cases, 

EPA provided responses to specific comments or groups of similar comments in the preamble to 

the final rulemaking. Rather than repeating those responses in this document, EPA has 

referenced the preamble. 

While every effort was made to include all significant comments related to 40 CFR Part 98, 

Subpart J—Ethanol Production in this volume, some comments inevitably overlap multiple 

subject areas. For comments that overlapped two or more subject areas, EPA assigned the 

comment to a single subject category based on an assessment of the principle subject of the 

comment. For this reason, EPA encourages the public to read the other volumes of this 

document with subject areas that may be relevant to 40 CFR Part 98, Subpart J—Ethanol 

Production. 

Please note, EPA has made the final decision not to include Subpart J- Ethanol Production as a 

distinct subpart in the Mandatory Greenhouse Gas Reporting Rule. For more information, please 

See section III. Other Proposed Source Categories of today’s preamble of the final rule. 
iv

The primary contacts regarding questions or comments on this document are: 

 Carol Cook (202) 343-9263 

 U.S. Environmental Protection Agency 

 Office of Atmospheric Programs 

 Climate Change Division 

 Mail Code 6207-J 

 1200 Pennsylvania Avenue, NW 

 Washington, D.C. 20460 

 ghgreportingrule@epa.gov 
v 

TABLE OF CONTENTS 

Section Page

1. DEFINITION OF SOURCE CATEGORY ........................................................................... 1 
1 

SUBPART J. — ETHANOL PRODUCTION 

1. DEFINITION OF SOURCE CATEGORY 

Commenter Name: Karen St. John 

Commenter Affiliation: BP America Inc. (BP) 

Document Control Number: EPA-HQ-OAR-2008-0508-0631.1 

Comment Excerpt Number: 70 

Comment: BP favors a technology-neutral approach to biofuels. We believe the biofuels 

definition used in the rule for “ethanol” should be replaced with a more technology neutral 

definition like “biofuels” in the Definitions section of Supbart J. “Ethanol” is a prescriptive 

definition that only defines one possible biofuels molecule. Advanced and cellulosic biofuels 

utilize a variety of different fuels molecules, which may have different performance 

characteristics than “ethanol.” BP, working in partnership with DuPont, is working to 

commercialize biobutanol, a biomass-derived molecule to improve the energy content and 

petroleum infrastructure compatibility of biofuels derived from a wide variety of biomass 

feedstocks. 

Response: EPA has made the final decision not to include Subpart J as a distinct subpart in the 

Mandatory Reporting of Greenhouse Gases Rule. See section III. Other Proposed Source 

Categories of today’s preamble for further explanation. Note, ethanol production facilities will 

still be required to report if they meet the threshold of 25,000 tons CO2e by aggregating 

emissions from all applicable sources covered by the rule, or if they meet the requirements of 

subpart PP. 

Ethanol is treated no differently than other biofuels in terms of reporting requirements for all 

sources but Subpart II - Industrial Wastewater Treatment. A definition for ethanol production 

facility is included in subpart II which mirrors that which was in Subpart J of the proposed rule. 

The facility types included in this definition are the ones that are known to have significant 

potential for emissions. Other biofuels are not included in this definition, but production 

facilities for these other fuels may be required to report under other Subparts. The rule does not 

require reporting of emissions from wastewater treatment processes associated with the 

production of other biofuels. EPA did not have sufficient data on wastewater treatment at these 

facility types to determine if any facilities would exceed the thresholds examined in this rule. 

Commenter Name: Bob Dinneen 

Commenter Affiliation: Renewable Fuels Association (RFA) 

Document Control Number: EPA-HQ-OAR-2008-0508-0494.1 

Comment Excerpt Number: 20 

Comment: Under the Proposed Rule, reporting is only required for those sources for which EPA 

has provided calculation methodologies. For ethanol production facilities, EPA proposes to 

require reporting of emissions only from three sources -- stationary fuel combustion, landfills 

and wastewater treatment. As such, emissions from ethanol fermentation should neither be 

calculated against the threshold nor be included in the reporting requirements. RFA agrees that 
this is the appropriate approach, which is consistent with EPA’s treatment of renewable fuels in 

general, and requests that EPA make this determination clear in the final rule. 

Response: EPA has made the final decision not to include Subpart J as a distinct subpart in the 

Mandatory Reporting of Greenhouse Gases Rule. See section III. Other Proposed Source 

Categories of today’s preamble for further explanation. Note, ethanol production facilities will 

still be required to report if they meet the threshold of 25,000 tons CO2e by aggregating 

emissions from all applicable sources covered by the rule, or if they meet the requirements of 

subpart PP. 

EPA agrees with the commenter that emissions from ethanol fermentation are not included in 

threshold calculations. 

Note that CO2 from fermentation, where captured, is in some cases reported under Subpart PP: 

Suppliers of CO2. 

Commenter Name: Bob Dinneen 

Commenter Affiliation: Renewable Fuels Association (RFA) 

Document Control Number: EPA-HQ-OAR-2008-0508-0494.1 

Comment Excerpt Number: 6 

Comment: It should be noted that in an inventory done by the Iowa Department of Natural 

Resources (“IDNR”) -- 2007 Greenhouse Gas Emissions from Selected Iowa Source Categories 

(Aug. 28, 2007) -- non-biogenic GHG emissions from ethanol plants paled in comparison to the 

largest emitters in the State. IDNR found that emissions ranged for 24 dry mill ethanol plants (22 

natural gas-fired and 2 coal-fired) ranged from 0.0114 to 0.1822 million mtCO2e (at 14-15). This 

can be compared to the emissions from the ten highest emitters in the State (all coal-fired 

utilities) which ranged from 1.31 to 9.14 million mtCO2e (at 19). The emissions from these ten 

facilities accounted for 69% of the total GHG emissions from fossil fuel combustion in the State. 

Response: EPA has made the final decision not to include Subpart J as a distinct subpart in the 

Mandatory Reporting of Greenhouse Gases Rule. See section III. Other Proposed Source 

Categories of today’s preamble for further explanation. Note, ethanol production facilities will 

still be required to report if they meet the threshold of 25,000 tons CO2e by aggregating 

emissions from all applicable sources covered by the rule, or if they meet the requirements of 

subpart PP. 

EPA disagrees with the commenter that ethanol facilities should not be included in the rule 

because they would not be a significant source of greenhouse gas emissions. Although 

emissions from these facilities may constitute a small percentage of national greenhouse gas 

emitted, even source categories that are not large sources at the national level can include 

facilities that do have large emissions relative to facilities across industries. See the preamble 

signed in 2009 section II(E) for EPA’s rationale on the selection of the reporting thresholds, and 

the TSD for ethanol for more information on the inclusion of this source category. 

While as a source category, ethanol production facilities may not be large sources of GHG 

emissions, the reporting of individual facilities having emissions exceeding the thresholds in the 

rule supports the goal of the reporting rule: to collect accurate and consistent data of sufficient 

quality to inform future policy and regulatory decisions. 

2 
Commenter Name: Bob Dinneen 

Commenter Affiliation: Renewable Fuels Association (RFA) 

Document Control Number: EPA-HQ-OAR-2008-0508-0494.1 

Comment Excerpt Number: 3 

Comment: In addition to stationary fuel combustion, EPA includes landfills and wastewater 

treatment as sources for which ethanol production facilities must report GHG emissions in 

accordance with the methodologies in the Proposed Rule. In 2007, EPA estimated that emissions 

from waste activities, including landfilling, wastewater treatment, and composting, were just 

over 2% of total U.S. GHG emissions. EPA, Inventory of U.S. Greenhouse Gas Emissions and 

Sinks: 1990-2007, at 8-1 (Apr. 15, 2009) (hereinafter referred to as “EPA GHG Inventory”), 

http://www.epa.gov/ climatechange/emissions/downloads09/Waste.pdf. Any emissions that may 

be attributable to landfills and wastewater treatment at ethanol facilities are likely to be only a 

tiny fraction of this small percent. First, EPA provides no support for its inclusion of landfill 

emissions for ethanol facilities. EPA indicates it has no data on landfilling at ethanol facilities 

“but it is believed that some of these facilities may have landfills with significant GHG 

emissions.” TSD for Ethanol Facilities, at 3. Such a statement is not adequate justification to 

impose reporting requirements on ethanol facilities with respect to such landfills, where they are 

likely to be de minimis. A typical ethanol plant is not expected to have a landfill. In 2007, based 

on EPA’s GHG Inventory and assuming no recovery, industrial landfills made up less than 12% 

of total CH4 emissions from landfills in the U.S., with municipal waste landfills making up the 

rest. EPA GHG Inventory, at 8-2. CH4 emissions from industrial landfills were estimated at 15.3 

teragrams CO2 equivalent (Tg CO2 Eq.) in 2006 and 15.4 Tg CO2 Eq. in 2007. Id. In its 

Technical Support Document for the Landfill Sector (“TSD for Landfill Sector”) (Feb. 4, 2009), 

EPA estimated that, in 2006, 14.6 million metric tons CO2 equivalent (mtCO2e) of CH4

emissions came from industrial landfills at pulp and paper facilities and food-processing facilities 

(at 4). That leaves only 0.7 million mtCO2e of CH4 emissions that can be attributed to all other 

industrial landfills. This is 4.6% of CH4 emissions from industrial landfills (15.3 Tg CO2 Eq.), 

0.5% of CH4 emissions from landfills in total (130.4 Tg CO2 Eq.), 0.4% of CH4 emissions from 

the waste sector generally (156.5 Tg CO2 Eq.), 0.1% of CH4 emissions in the U.S. (582.0 Tg CO2

Eq.), and 0.0099% of total GHG emissions in the U.S. (7,051.1 Tg CO2 Eq.) (for 2006). Based 

on the information available, industrial landfills at ethanol facilities can only be an insignificant 

part of U.S. GHG emissions, insufficient to require reporting under the rule. Second, the only 

discussion on emissions from ethanol facilities that EPA provides in its support documents for 

the Proposed Rule is on EPA’s estimates of emissions from wastewater treatment at ethanol 

facilities, but this information also is not sufficient to support the inclusion of these emissions in 

the rule. Even here, EPA is making assumptions as to the number of facilities that contain 

wastewater treatment and the potential emissions. More important, as with landfill emissions, 

even based on EPA’s assumptions, emissions from wastewater treatment at ethanol production 

facilities are insignificant. EPA estimated that wastewater treatment systems account for only 4% 

of total anthropogenic CH4 emissions. Technical Support Document for Wastewater Treatment: 

Proposed Rule for Mandatory Reporting of Greenhouse Gases, at 4, (Feb. 4, 2009) (“TSD for 

Wastewater Treatment”). EPA estimated that CH4 emissions from wastewater treatment at 

ethanol production facilities were less than 1% of total CH4 emissions from industrial wastewater 

treatment. TSD for Ethanol Facilities, at 3. EPA estimated only 1 ethanol facility to have 

emissions from wastewater treatment to exceed 25,000 mtCO2e. TSD for Wastewater Treatment, 

at 7. Based on EPA’s GHG Inventory, the estimated emissions from wastewater treatment at 

ethanol facilities is de minimis. EPA estimated that CH4 emissions totaled 68,200 mtCO2e in 

3 
2006. TSD for Ethanol Facilities, at 3. This is 0.27% of total CH4 emissions from wastewater 

treatment (24.5 Tg CO2 Eq.), 0.044% of total CH4 emissions from the waste sector generally 

(156.5 Tg CO2 Eq.), 0.012% of total CH4 emissions in the U.S. (582.0 Tg CO2 Eq.), and 

0.00096% of total GHG emissions in the U.S. (7,051.1 Tg CO2 Eq.) (for 2006). Based on the 

information available, emissions associated with wastewater treatment at ethanol facilities makes 

up an insignificant part of GHG emissions, insufficient to require reporting under the rule. EPA 

simply provides insufficient justification for including emissions from landfills and wastewater 

treatment at ethanol facilities as part of their reporting requirements.14 As such, these sources 

should be removed from the reporting requirements for ethanol production facilities under 

Subpart J of the Proposed Rule (Proposed Section 98.102(b) and (c)). 

Response: EPA has made the final decision not to include Subpart J as a distinct subpart in the 

Mandatory Reporting of Greenhouse Gases Rule. See section III, Other Proposed Source 

Categories of today’s preamble for further explanation. Note, ethanol production facilities will 

still be required to report if they meet the threshold of 25,000 tons CO2e by aggregating 

emissions from all applicable sources covered by the rule, or if they meet the requirements of 

subpart PP. 

With regard to the lack of information on landfilling of wastes at ethanol production facilities, it 

is expected that data collected through this rule will improve our understanding of emissions 

sources in various industries. Ethanol production facilities without landfills will not be required 

to report data for Subpart TT. In addition, Subpart TT in the final rule further clarifies that 

industrial landfills that receive organic waste must report only if their design capacity is 300,000 

Mg of waste or greater. 

See the preamble signed in 2009 (74 FR (page 56317)) for response to comments on de minimus 

exclusions. With regard to the percentage of national greenhouse gas emitted from ethanol 

production facilities, even source categories that are not large sources at the national level can 

include facilities that have large emissions relative to facilities across industries. 

Commenter Name: Bob Dinneen 

Commenter Affiliation: Renewable Fuels Association (RFA) 

Document Control Number: EPA-HQ-OAR-2008-0508-0494.1 

Comment Excerpt Number: 2 

Comment: EPA provides little information on its analysis of ethanol production facilities in 

support of the requirements for this source category in the Proposed Rule. Although EPA 

provides estimates as to the number of facilities that may be covered (based only on 140 total 

facilities), EPA provides no total emissions estimates for ethanol facilities. Ethanol is one of only 

two source categories for which EPA provides no such emission estimates to support their 

inclusion in the listed source categories (food processing being the other). See Technical Support 

Document for Reporting Thresholds: Proposed Rule for Mandatory Reporting of Greenhouse 

Gases, Table 5-8 (Mar. 8, 2009) (“TSD for Reporting Thresholds”) (OAR-2008-0508-0046). 

RFA questions EPA’s claim that “[e] stimates of total national emissions from landfills and 

stationary combustion at ethanol facilities are unavailable.” Technical Support Document for 

Ethanol Facilities: Proposed Rule for Mandatory Reporting of Greenhouse Gases, at 3 (Feb. 4, 

2009) (“TSD For Ethanol Facilities”) (OAR-2008- 0508-0010). In the Proposed Rule, EPA notes 

that “[d]ata on stationary fuel combustion were used to estimate the minimum number of 

facilities that would meet each of the facility-level thresholds examined.” 74 Fed. Reg. at 16,500. 

4 
We did not find these estimates in the record. The only information provided in the TSD and the 

Regulatory Impact Analysis was on wastewater treatment. As such, RFA cannot adequately 

respond to EPA’s decision to include ethanol facilities as a source category and to the potential 

impacts of the rule on ethanol facilities. EPA must provide this information to provide notice and 

an adequate opportunity for comment. Therefore, EPA should include this information in the 

record and reopen the comment period, providing sufficient time for interested members of the 

public to review the data and submit comments. 

Response: EPA has made the final decision not to include Subpart J as a distinct subpart in the 

Mandatory Reporting of Greenhouse Gases Rule. See section III, Other Proposed Source 

Categories of today’s preamble for further explanation. Note, ethanol production facilities will 

still be required to report if they meet the threshold of 25,000 tons CO2e by aggregating 

emissions from all applicable sources covered by the rule, or if they meet the requirements of 

subpart PP. For information on stationary combustion at ethanol facilities, see the Technical 

Support Document for Ethanol Facilities. 

Commenter Name: John Seltz 

Commenter Affiliation: Minnesota Pollution Control Agency (MPCA) 

Document Control Number: EPA-HQ-OAR-2008-0508-0465.1 

Comment Excerpt Number: 5 

Comment: Under the proposed rule, ethanol facilities that emit more than 25,000 CO2-

equivalent tons per year of greenhouses must report. The proposed rule does not reference 

biogenic CO2 emissions from fermentation at the facilities. Biogenic CO2 emissions from the 

combustion of biomass are reportable under the federal reporting rule. This seems inconsistent. 

The MPCA is interested in understanding the basis for EPA’s reasoning on this issue. 

Response: EPA has made the final decision not to include Subpart J as a distinct subpart in the 

Mandatory Reporting of Greenhouse Gases Rule. See section III, Other Proposed Source 

Categories of today’s preamble for further explanation. Note, ethanol production facilities will 

still be required to report if they meet the threshold of 25,000 tons CO2e by aggregating 

emissions from all applicable sources covered by the rule, or if they meet the requirements of 

subpart PP. 

With respect to emissions from combustion of biomass, see the response to comment for the rule 

signed in 2009, EPA-HQ-OAR-2008-0508-0690.1, excerpt 1 in Volume 1. For the purpose of 

the reporting rule, facilities are not to include CO2 emissions associated with biomass 

combustion when determining whether they meet the requirements of 98(a)(2), but if they do 

meet the requirements of 98(a)(2), they are required to separately report emissions associated 

with the biomass combustion at the facility. 

With regard to reporting of emissions from fermentation by ethanol production facilities, please 

see the response to comment EPA-HW-OAR-2008-0508-0494.1, excerpt 20. 

Commenter Name: Bob Dinneen 

Commenter Affiliation: Renewable Fuels Association (RFA) 

Document Control Number: EPA-HQ-OAR-2008-0508-0494.1 

Comment Excerpt Number: 21 

5 
Comment: EPA has properly focused on non-biogenic anthropogenic sources of GHG emissions 

in the Proposed Rule. Ethanol is produced from biomass, and the carbon in biomass is of a 

biogenic origin --meaning that it was recently contained in living organic matter. For example, 

emissions associated with ethanol fermentation are not counted against GHG emissions in Iowa’s 

reporting program because they are considered biogenic emissions. Also, EPA has found that 

“the CO2 emitted from biomass-based fuels combustion does not increase atmospheric CO2

concentrations, assuming the biogenic carbon emitted is offset by the uptake of CO2 resulting 

from the growth of new biomass.” 74 Fed. Reg. 24,904, 25,039 (May 26, 2009). This also 

applies to biogenic emissions from fermentation. 

Response: EPA has made the final decision not to include Subpart J as a distinct subpart in the 

Mandatory Reporting of Greenhouse Gases Rule. See section III. Other Proposed Source 

Categories of today’s preamble for further explanation. Note, ethanol production facilities will 

still be required to report if they meet the threshold of 25,000 tons CO2e by aggregating 

emissions from all applicable sources covered by the rule, or if they meet the requirements of 

subpart PP. 

With respect to emissions from combustion of biomass, see the response to comment for the rule 

signed in 2009, EPA-HQ-OAR-2008-0508-0690.1, excerpt 1 in Volume 1. With respect to 

emissions associated with ethanol fermentation, see the response to comment EPA-HQ-OAR2008-0508-0494.1, excerpt 20. Note that this rule does not make a determination on whether 

CO2 from biomass is offset by uptake of CO2 from the growth of new biomass. 

Commenter Name: Steven M. Pirner 

Commenter Affiliation: South Dakota Department of Environment and Natural Resources (SD 

DENR) 

Document Control Number: EPA-HQ-OAR-2008-0508-0576 

Comment Excerpt Number: 3 

Comment: EPA is not proposing to require reporting by suppliers of biomass-based fuels, or 

renewable fuels, due to the fact that greenhouse gases emitted upon combustion of these fuels are 

traditionally taken into account at the point of biomass production. EPA is seeking comment on 

this approach and notes that producers of some biomass-based fuels (e.g., ethanol) would be 

subject to reporting requirements for their on-site emissions. SD DENR agrees with this 

approach because it avoids double counting of greenhouse gas emissions and meets the objective 

of the rule to collect comprehensive and accurate data which will be used to develop future 

policies and climate change legislation. 

Response: EPA has made the final decision not to include Subpart J as a distinct subpart in the 

Mandatory Reporting of Greenhouse Gases Rule. See section III. Other Proposed Source 

Categories of today’s preamble for further explanation. Note, ethanol production facilities will 

still be required to report if they meet the threshold of 25,000 tons CO2e by aggregating 

emissions from all applicable sources covered by the rule, or if they meet the requirements of 

subpart PP. 

The final rule, like the proposed rule does not require suppliers to report the biomass fuels they 

supply, but does require reporting of certain emissions from other onsite sources at biofuels 

facilities that meet the thresholds in 98.2. With regard to reporting of direct emissions from 

6 
combustion of biomass, see the response to comment EPA-HQ-OAR-2008-0508-0465.1, excerpt 

5. 

Commenter Name: Karen St. John 

Commenter Affiliation: BP America Inc. (BP) 

Document Control Number: EPA-HQ-OAR-2008-0508-0631.1 

Comment Excerpt Number: 69 

Comment: BP believes that EPA should expand the coverage of its rule to include all “biofuel” 

production facilities that combust fossil fuel-based fuels so long as they meet the reporting 

threshold, and not limit the rule to “ethanol” production facilities only. 

Response: EPA has made the final decision not to include Subpart J as a distinct subpart in the 

Mandatory Reporting of Greenhouse Gases Rule. See section III. Other Proposed Source 

Categories of today’s preamble for further explanation. Note, ethanol production facilities will 

still be required to report if they meet the threshold of 25,000 tons CO2e by aggregating 

emissions from all applicable sources covered by the rule, or if they meet the requirements of 

subpart PP. 

All facilities, regardless of the sector, must report direct emissions from stationary combustion 

sources if they have stationary combustion source emissions above the threshold in the rule or 

contain other source categories covered by the rule. With regard to the inclusion of biofuels 

other than ethanol in industrial wastewater treatment requirements, please see response to 

comment EPA-HQ-OAR-2008-0508-0631.1, excerpt 70. 

Commenter Name: J. Jared Snyder 

Commenter Affiliation: New York State Department of Environmental Conservation 

Document Control Number: EPA-HQ-OAR-2008-0508-1184 

Comment Excerpt Number: 10 

Comment: The Department recommends mandatory reporting of GHG emissions from the 

fermentation process. Significant carbon dioxide emissions from the fermentation process 

provide a pure stream of carbon dioxide that is typically vented to the atmosphere, but may be 

captured and sequestered or sold for other industrial applications. Accurate accounting of these 

emissions is necessary for determining net CO2 emissions from ethanol production. 

Response: EPA has made the final decision not to include Subpart J as a distinct subpart in the 

Mandatory Reporting of Greenhouse Gases Rule. See section III. Other Proposed Source 

Categories of today’s preamble for further explanation. Note, ethanol production facilities will 

still be required to report if they meet the threshold of 25,000 tons CO2e by aggregating 

emissions from all applicable sources covered by the rule, or if they meet the requirements of 

subpart PP. 

With respect to emissions associated with ethanol fermentation, see the response to comment 

EPA-HQ-OAR-2008-0508-0494.1, excerpt 20. EPA agrees that there may be significant CO2

emissions from these operations and that these emissions may be captured and sequestered or 

sold for other industrial applications. To gather more information on these practices, EPA 

requires Suppliers of CO2 to report under Subpart PP. 

7 
Commenter Name: Bob Dinneen 

Commenter Affiliation: Renewable Fuels Association (RFA) 

Document Control Number: EPA-HQ-OAR-2008-0508-0494.1 

Comment Excerpt Number: 5 

Comment: Several States already require reporting from ethanol facilities. For example, Iowa 

requires GHG reporting from Title V sources and ethanol facilities. EPA should give facilities 

the option of utilizing reports already being submitted to States. 

Response: EPA has made the final decision not to include Subpart J as a distinct subpart in the 

Mandatory Reporting of Greenhouse Gases Rule. See section III. Other Proposed Source 

Categories of today’s preamble for further explanation. Note, ethanol production facilities will 

still be required to report if they meet the threshold of 25,000 tons CO2e by aggregating 

emissions from all applicable sources covered by the rule, or if they meet the requirements of 

subpart PP. 

See the preamble signed in 2009 (FR 74, (page 56283)) for the response on the relationship of this 

rule to other programs, and EPA's commitment to working with States when implementing the 

final reporting rule. 

Commenter Name: Bob Dinneen 

Commenter Affiliation: Renewable Fuels Association (RFA) 

Document Control Number: EPA-HQ-OAR-2008-0508-0494.1 

Comment Excerpt Number: 22 

Comment: There are several ethanol plants that are capturing CO2 from the fermentation 

process and removing these emissions from the atmosphere. The capture and removal of CO2

produced by fermentation is a net reduction in atmospheric CO2, not just a reduction in CO2

emissions. These facilities should be allowed to count these emissions against their total for 

determining whether the threshold is met, and they should be included in any reports to EPA. 

Response: EPA has made the final decision not to include Subpart J as a distinct subpart in the 

Mandatory Reporting of Greenhouse Gases Rule. See section III. Other Proposed Source 

Categories of today’s preamble for further explanation. Note, ethanol production facilities will 

still be required to report if they meet the threshold of 25,000 tons CO2e by aggregating 

emissions from all applicable sources covered by the rule, or if they meet the requirements of 

subpart PP. 

With respect to CO2 emissions associated with ethanol fermentation, see the response to 

comment EPA-HQ-OAR-2008-0508-1184, excerpt 10. At this time, this rule does not address 

removals of CO2. 

8 
9 

Commenter Name: Matthew Frank 

Commenter Affiliation: Wisconsin Department of Natural Resources 

Document Control Number: EPA-HQ-OAR-2008-0508-1062.1 

Comment Excerpt Number: 9 

Comment: The framework outlined in the proposed rule for GHG reporting for ethanol 

production is straightforward, understandable and comprehensive. If EPA requires the 

calculation of these emissions, please identify the emission factors to be used. 

Response: EPA has made the final decision not to include Subpart J as a distinct subpart in the 

Mandatory Reporting of Greenhouse Gases Rule. See section III. Other Proposed Source 

Categories of today’s preamble for further explanation. Note, ethanol production facilities will 

still be required to report if they meet the threshold of 25,000 tons CO2e by aggregating 

emissions from all applicable sources covered by the rule, or if they meet the requirements of 

subpart PP. 

Emission factors for wastewater treatment are listed in Table II-1 of subpart II. Wastewater 

treatment emissions are calculated using equations II-1 through II-6 listed § 98.353. The 

emission factors for stationary combustion are listed in Tables C-1 and C-2 of subpart C and 

emissions are calculated using the equations listed in § 98.33. Finally the emission factors for 

industrial landfills are located in Table TT-1 of subpart TT and emissions are calculated using 

equation TT-6.