August 2013 

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Greenhouse Gas Reporting Program (Revisions to Reporting

and Recordkeeping Requirements, and Proposed Confidentiality 

Determinations Proposed Rule)

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection

Greenhouse Gas Reporting Program (Revisions to Reporting

and Recordkeeping Requirements, and Proposed Confidentiality 

Determinations Proposed Rule); OMB control number 2060-0629; ICR 

number 2300.12 .

1(b) Short Characterization/Abstract

This supporting statement addresses information collection 

activities that would be imposed by these proposed revisions to 

the greenhouse gas reporting rule (40 CFR part 98; henceforth 

referred to as Part 98), finalized by EPA on October 30, 2009

(74 FR 56260). Part 98, which became effective on December 29, 

2009, requires that certain facilities and suppliers emitting 

above certain threshold levels of carbon dioxide (CO2) equivalent 

(CO2e) monitor and report emissions of greenhouse gases (GHGs).

These proposed revisions address how these emissions are 

reported and recorded.

In a July 7, 2010 action, the EPA proposed that data 

elements categorized as “inputs to emission equations” are 

emission data. The CAA precludes “emission data” from being 

treated as confidential. Due to stakeholder concerns regarding 

potential competitive harm that would result from public release 

of these data elements, EPA deferred reporting of these data 
August 2013 

elements (see August 25, 2011 final action, 76 FR 53057) to 

allow EPA time to complete an evaluation of the potential impact 

from the public release of these data elements (see 76 FR 

53060). Reporting of certain of these data elements was deferred 

to March 31, 2013, and reporting of the remainder of these data 

elements was deferred to March 31, 2015. 

Based on its evaluation of the data elements for which 

reporting was deferred to March 31, 2015 (henceforth referred to 

as “inputs to equations” data elements”)1, EPA is proposing 

amendments to reporting and recordkeeping requirements for 

reporters subject to 24 subparts that require reporting of these 

inputs to emission equations. These revisions include:

 For reporters subject to 24 subparts that use “inputs to 

equations” data elements to calculate reported GHGs, 

replacing current reporting and recordkeeping requirements 

(previously included in an information collection request 

approved by OMB) with new requirements, as follows:2

o Replacing the requirement to report “inputs to 

equations” data elements via the web-based Electronic 

Greenhouse Gas Reporting Tool (e-GGRT) (i.e., entering

these data into e-GGRT), and, instead, requiring that 

these data be entered into an inputs verification tool3

 

1 Using the same evaluation procedures, we evaluated all data elements for 

which reporting was deferred to March 31, 2013 (Table A-6 to Part 98) and 

took no further action. As a result, applicable facilities were required to 

report these data by April 1, 2013.

2 Stationary fuel combustion sources subject to subpart C (e.g., individual 

units, aggregations of units, common pipes, or common stacks) are not 

affected by the proposed amendments if they meet both of the following 

criteria: (1) the stationary fuel combustion source contains at least one 

combustion unit connected to a fuel-fired electric generator that has been 

granted access by the Public Utilities Commission to deliver power to the 

local or regional electric power grid (excluding generators connected to 

combustion units subject to subpart D of Part 98); and (2) the stationary 

fuel combustion source is located at a facility for which the sum of the 

nameplate capacities for all such electric generators is greater than or 

equal to 1 megawatt electric output. Refer to Section III.A.3 of this 

preamble for a discussion of the EPA’s rationale for proposing that 

combustion units meeting these criteria not be affected by the proposed 

amendments.

3 All data reported in the annual report via e-GGRT are retained in e-GGRT. 

Data entered into the inputs verification tool would not be reported (or 

otherwise accessible) to EPA. The tool would use entered data to conduct 
August 2013 

provided in e-GGRT. This proposed amendment would not 

apply to reporters for any reported GHG for which the 

reporter uses a CEMS or an EPA-approved alternative 

method (as allowed under sections 98.33(a)(5), 

98.53(a)(2), and 98.223(a)(2) of Part 98) to 

calculate the reported GHG value.

o Regarding the current requirement that reporters keep 

records of these “inputs to equations” data elements, 

changing the format of these records to be a file 

generated by the inputs verification tool, which lists 

these entered data. The current requirement is to 

maintain these records in any format allowed under 

Subpart A of Part 98.

o Lengthening the record retention period from three to 

five years for all records maintained under Part 98.

 Requiring reporting of 26 new data elements.

These activities would enable EPA to verify emissions and 

ensure compliance with the GHGRP.

Compared with the estimated respondent burden identified in 

the information collection for the GHGRP currently approved by 

OMB, this proposed information collection would increase the 

estimated respondent burden by 10,786 hours and $620,140. This 

increase reflects the additional costs incurred for: (1) 5,736 

respondents from the one-time activity of training to use the 

inputs verification tool and (2) 781 respondents from the ongoing activity of reporting the new data elements.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

The EPA is proposing this information collection under its 

existing CAA authority provided in CAA section 114. As stated in 

the October 30, 2009 preamble to Part 98 (74 FR 56260), CAA 

 

electronic verification of reported data and generate a verification summary 

made available to EPA for verification purposes. All “inputs to equations” 

data elements not reported in the annual report would be kept on record by 

reporters. Refer to section 5(b) for further discussion of the proposed tool. 
August 2013 

section 114(a)(1) provides EPA broad authority to require the 

information proposed to be gathered by Part 98 because such data 

would inform and are relevant to EPA’s carrying out a wide 

variety of CAA provisions. Additionally, signed into law on 

December 26, 2007, the FY2008 Consolidated 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.”

Sections 114 and 208 of the Clean Air Act (CAA) provide EPA 

authority to require the information mandated by the GHGRP 

because such data will inform and are relevant to future policy 

decisions. CAA section 114(a)(1) authorizes the Administrator to 

require emissions sources, persons subject to the CAA, or 

persons whom the Administrator believes may have necessary 

information to report emissions and provide such other 

information the Administrator requests for the purposes of 

carrying out any provision of the CAA. For these reasons, the 

Administrator may request that a person, on a one-time, periodic 

or continuous basis, establish and maintain records, make 

reports, and, among other things, provide such information the 

Administrator may reasonably require. Because EPA does not yet 

know the specific policies that will be adopted, the data 

reported under the GHGRP is of sufficient quality to inform 

policy and program development. 

2(b) Practical Utility/Users of the Data

This information collection collects information from 

facilities that directly emit GHGs and from suppliers of 
August 2013 

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

comprehensive GHG data reported directly from large facilities 

and suppliers across the country are now easily accessible to 

the public at: http://ghgdata.epa.gov/ghgp/main.do. Reporting 

entities use uniform methods for estimating emissions, which 

enables data to be compared and analyzed. EPA’s online data 

publication tool allows users to view and sort GHG data for 

calendar year 2010 from over 6,000 entities in a variety of 

ways, including by location, industrial sector, and the type of 

GHG emitted. 

Data collection in the GHGRP complements the Inventory of 

U.S. Greenhouse Gas Emissions and Sinks (Inventory) and can help 

EPA transition to use of the 2006 Intergovernmental Panel on 

Climate Change (IPCC) Guidelines for National Greenhouse Gas 

Inventories. 

Transparent, public data on emissions allows for 

accountability of polluters to the public stakeholders who bear 

the cost of the pollution. This data resource provides a 

critical tool for communities to identify nearby sources of GHGs 

and provide information to state and local governments.

The standardization of GHG data provides businesses with 

the necessary information to benchmark themselves against 

similar facilities, better understand their relative standing 

within their industry, and achieve and disseminate their 

environmental achievements. Businesses and other innovators can 

use the data to determine their GHG footprints, find cost- and 

fuel-saving efficiencies that reduce greenhouse gas emissions 

(e.g., through energy audits or other forms of assistance), and 

foster technologies to protect public health and the 

environment. 

The facility-specific GHG emissions data improve the 

understanding of the factors that influence GHG emission rates 
August 2013 

as well as the actions that facilities take to reduce emissions. 

The facility-based data can be aggregated to the corporate level 

in order to track emission trends from industries, within 

industries, and across industries over time, particularly in 

response to policies and potential regulations. 

Information collected from the oil and gas facilities (in 

subpart W) and CO2 injection facilities (in subparts RR and UU) 

allows EPA to gain a better understanding of the entire CO2

capture and sequestration (CCS) system.

Information collected from fluorocarbons allows EPA to 

assess the overall volume and importance of compounds for which 

global warming potentials (GWPs) have not been evaluated and 

help identify which compounds should have their GWPs evaluated 

first. In addition, historical reports in tons of chemical can 

be converted into CO2e, provided GWPs have been identified for 

these compounds. Without this comprehensive reporting 

requirement, such historical information could be lost. 

The GHGRP is not intended to be a survey and the 

respondents affected by the program are not intended to be a 

statistical sample of a larger universe of entities. EPA does 

not intend to use the data collected under the GHGRP to 

characterize non-reporting entities or to draw statistical 

inferences about a larger population.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION

CRITERIA

3(a) Nonduplication

The new information proposed to be collected under the 

proposed revisions are 26 new data elements affecting 10 

subparts of Part 98 (refer to section 4(b) for a list of these 

data elements). These proposed new data elements consist 
August 2013 

primarily of quantities that provide information on the activity 

level at the facility, emission factors used, characteristics of 

carbon-containing streams, and other process information that 

would provide key information for verification, including 

confirming that emissions are appropriate for a given activitylevel and estimating expected emissions based on data provided.

These proposed new reporting elements, described above, are the 

same types of industry data currently collected under the GHGRP. 

EPA previously evaluated these types of industry data currently 

collected under Part 98, and concluded that they do not 

duplicate other information collections, as described below. 

This conclusion, as described below, applies to the proposed new 

data elements as well.

In developing the GHGRP, EPA reviewed monitoring methods,

including:

 Federal programs within the United States, such as the 

Inventory, the U.S. Department of Energy’s (DOE’s) Energy 

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

Acid Rain Program, EPA Natural Gas STAR Program, and 

voluntary GHG partnership programs;

 State and regional GHG reporting programs, such as The 

Climate Registry, the Regional Greenhouse Gas Initiative, 

the Western Regional Air Partnership, and programs in 

several states including California, New Mexico, 

Connecticut, and New Jersey;

 Reporting protocols developed by nongovernmental 

organizations, such as the World Resources 

Institute/World Business Council for Sustainable 

Development; and 

 Programs from industrial trade organizations, such as the 

Interstate Natural Gas Association of America’s GHG 

Emission Estimation Guidelines, the American Petroleum 

Institute’s Compendium of GHG Estimation Methodologies 

for the Oil and Gas Industry, and the World Business 

Council for Sustainable Development’s Cement 
August 2013 

Sustainability Initiative’s CO2 Accounting and Reporting 

Standard for the Cement Industry. 

These programs led the way in reporting of GHG emissions 

before the federal government acted and assisted in quantifying 

the GHG reductions achieved by various policies. Many of these 

programs collect different or additional data as compared to the 

GHGRP and this proposal. For example, state programs may include 

different data elements to support other programs (e.g., 

offsets). While some programs collect similar information on GHG 

emissions, the Agency has determined that the GHGRP supplements

and complements, rather than duplicates, existing programs’ 

data. Further, EPA has made significant efforts over the past 

four years to facilitate the reporting in the event a single 

entity has to report both the federal and state level. For 

example, EPA has supported efforts by the California Air 

Resources Board to harmonize the reporting of information under 

California’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 eGGRT.

Documentation of EPA’s review of GHG monitoring protocols 

used by federal and state voluntary and mandatory GHG programs 

as well as GHG reporting rules can be found in the docket at 

EPA-HQ-OAR-2008-0508-056. For further discussion on the 

relationship of the GHGRP to other programs, please refer to the 

preambles of each of the GHGRP rulemakings, the June 6, 2008 

memorandum entitled Review of Existing Programs (which can be 

found in the docket at EPA-HQ-OAR-2008-0508-0052), and the 

January 27, 2009 memorandum entitled Review of Existing State 

Greenhouse Gas Reporting Rules (which can be found in the docket 

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

below:
August 2013 

 A number of EPA’s voluntary partnership programs include 

a GHG emissions and/or reductions reporting component 

(e.g., Natural Gas STAR program, etc.). However, the 

GHGRP has much broader coverage than the voluntary 

programs and therefore helps EPA learn more about 

emissions from facilities not included in current 

programs.

 EPA reviewed the Inventory, which is an annual 

comprehensive top-down assessment of national greenhouses 

gas emissions. While the Inventory is generally compiled 

from national surveys (i.e., not broken down at the 

geographic or facility level), the GHGRP focuses on 

bottom-up data from individual facilities that exceed 

appropriate thresholds. The bottom-up approach to data 

collection in the GHGRP can help reduce uncertainty in 

emissions estimates for specific industries, and more 

broadly, helps EPA transition to use of the 2006 IPCC 

Guidelines for National Greenhouse Gas Inventories, which 

will be required to meet international reporting 

obligations under the United Nations Framework Convention 

on Climate Change in the near future.

As noted in the ICR for the 2009 GHG Reporting Rule, a

number of programs at the state, tribal, territorial, and local 

level require emission sources in their respective jurisdictions 

to monitor and report GHG emissions. To reduce burden on 

reporters and program agencies, the Agency plans to share

reported data, with the exception of any information determined 

to be CBI, with relevant agencies or approved entities using, 

where practical, shared tools, and infrastructure.

Based on this evaluation, this information collection 

request does not duplicate other information collections.

3(b) Public Notice Required Prior to Information Collection 

Request (ICR) Submissions to OMB

A public notice of this collection is provided in the 

Federal Register notice of proposed rulemaking for the Revisions 
August 2013 

to Reporting and Recordkeeping Requirements, and Proposed 

Confidentiality Determinations under the Greenhouse Gas 

Reporting Program.

3(c) Consultations

In 2010, the EPA proposed confidentiality determinations 

for the majority of data elements required to be reported under 

the GHGRP, as well as for the majority of source categories 

covered by the program. In a July 7, 2010 action, the EPA 

proposed that data elements categorized as “inputs to equations” 

data elements are emission data. The CAA precludes “emission 

data” from being treated as confidential. As further discussed 

in section 1(b), based on subsequent industry concerns regarding 

the potential release of data elements categorized as “inputs to

equations” data elements, EPA deferred reporting of these data 

elements to allow EPA to complete its evaluation of the 

potential impact from the public release of these data elements

and, if appropriate, to propose amendments to Part 98 (see 75 FR 

81355, December 27, 2010). After having completing its 

evaluation of the potential impact, EPA is proposing the 

amendments summarized in section 1(b) to address this issue,

while allowing EPA to verify emissions and ensure compliance 

with the program.

The public will be provided an opportunity during the 

comment period for the proposed rulemaking to review and comment 

on this burden estimate.

3(d) Effects of Less Frequent Collection

The frequency for reporting emissions information to EPA 

under the GHGRP was originally established to minimize the 

burden on owners and operators of affected facilities, while 

ensuring that the GHGRP collects facility-specific data of 
August 2013 

sufficient quality to achieve the Agency’s objectives. The GHGRP

requires annual reporting, except for a limited number of 

facilities that are already subject to more frequent reporting 

requirements. This reporting frequency remains the same in these 

proposed revisions to Part 98.

Annual reporting will ensure that data are verified and 

made available to the public, as authorized by the CAA, and use 

the data for the purposes described in section 2(b). If the 

information collection were not carried out on this schedule, 

the Agency would not be able to develop an informed tracking 

system of trends in GHG emissions across the country. 

3(e) General Guidelines

None of the guidelines in 5 CFR 1320.5 would be exceeded,

with the exception of requiring records to be maintained for 

more than three years. EPA is proposing to require that 

reporters using the proposed inputs verification tool retain

records for five years. Given the proposed verification approach 

described in Section 1(b), EPA considered whether the current 

record retention period and record format requirements would be 

sufficient to allow EPA to perform data verification. We 

considered:

 The time we would need to follow up with reporters to 

further verify reported GHG emissions.

 The desirability of retaining multiple years of data 

records to allow for appropriate assessment of compliance 

and for analyses of trends for policy analysis purposes.

 The format of records, and whether the current format would 

be adequate for our verification process. For example, we 

considered whether records of “inputs to equations” data 

elements contained in multiple separate documents (as 

currently allowed under Part 98) would allow an EPA 
August 2013 

inspector to efficiently analyze the consistency of the 

data elements and use the data elements to perform 

calculations to confirm reported GHG emissions.

Because there may be more direct follow-up activities under 

this alternative verification approach, we are proposing to 

extend the record retention period from 3 to 5 years. We have 

determined that 5 years is reasonable given the large number of 

reporters under the subparts identified in Table 2 of this 

preamble (over 2,000 facilities) and the likely increase in 

follow-up activities. It would be important that relevant 

records are available to the EPA for follow-up activities with 

facilities, including on-site audits if necessary, regarding 

potential errors, discrepancies, or questions. Should an EPA 

inspector visit a facility, it would be important to be able to 

examine not only the current year’s records but those from 

previous years as well, because previous years’ data would 

provide year-to-year comparisons, which are useful for verifying 

the current year’s data. A 5-year record retention period would 

ensure the availability of relevant records for the follow-up 

activities described above. 

3(f) Confidentiality

Data collected under the GHGRP must be made available to 

the public unless the data qualify for CBI treatment under the 

CAA and EPA regulations. The CAA precludes “emission data” from 

being treated as confidential. For data reported under the CAA 

that are not emission data, EPA typically makes CBI 

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

to the large number of entities reporting under the GHGRP and 

the large number of data reporting elements, EPA previously 

concluded that case-by-case determinations would not result in 

timely release of emission and other non-CBI data (see proposed 
August 2013 

CBI rule, July 7, 2010, 75 FR 39094). Therefore, EPA has 

published CBI determinations for most information reported under 

the GHGRP (May 26, 2011, 76 FR 30782; August 13, 2012, 77 FR 

48072; August 24, 2012, 77 FR 51477; and in this proposed rule). 

These CBI determinations specify which data reporting elements 

in Part 98: (1) are CBI, (2) are non-CBI, and (3) are emission 

data (i.e., ineligible for CBI protection). All data determined 

by EPA to be CBI are safeguarded in accordance with regulations 

in 40 CFR Chapter 1, Part 2, Subpart B.

3(g) Sensitive Questions

The revisions to reporting or recordkeeping requirements in 

the proposed revisions to Part 98 do not include sensitive 

questions.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

The respondents in this information collection include 

owners and operators of facilities that must report “inputs to 

equations” data elements for which reporting is deferred to 2015

to comply with Part 98. To facilitate the analysis, EPA has 

divided respondents into groups that align with the source 

categories identified in Part 98. These industry sectors (i.e., 

GHGRP subparts) participating in this information collection are 

listed in subsection 4(a). Additionally this section provides

the data elements required of program participants and the 

activities in which participants must engage to collect, assess, 

calculate, and in some cases submit the required data elements. 

4(a) Respondents/North American Industrial Classification System 

(NAICS) Codes

The proposed revisions to Part 98 affect facilities subject 

to the subparts (i.e., industry sectors) listed in the following 
August 2013 

table. Reporting facilities include, but are not limited to: (1)

those operating one or more units that exceed the CO2e threshold 

for certain industry sectors listed below (and listed in Table 

A-3 of 40 CFR 98.2(a)(1)), and (2) those included in certain

industry sectors (listed below) for which all facilities must 

report, such as petroleum refineries. Industry sectors are 

listed by the corresponding subpart of Part 98 and NAICS code 

for reference. The NAICS codes are not exhaustive, but rather 

provide a list of facilities and suppliers likely to be 

affected.

Part and Subpart NAICS code(s)

40 CFR Part 98

C. General 

Stationary Fuel 

Combustion Sources

Facilities operating boilers, process heaters, 

incinerators, turbines, and internal combustion 

engines: 321 Manufacturers of lumber and wood 

products; 322 Pulp and paper mills; 325 Chemical 

manufacturers; 324 Petroleum refineries, and 

manufacturers of coal products; 316, 326, 339 

Manufacturers of rubber and miscellaneous plastic 

products; 331 Steel works, blast furnaces; 332 

Electroplating, plating, polishing, anodizing, and 

coloring; 336 Manufacturers of motor vehicle parts and 

accessories; 221 Electric, gas, and sanitary services; 

622 Health services; 611 Educational services

E. Adipic Acid 

Production

325199 Adipic acid manufacturing facilities

F. Aluminum 

Production

331312 Primary Aluminum production facilities

G. Ammonia 

Manufacturing

325311 Anhydrous and aqueous ammonia manufacturing 

facilities

H. Cement 

Production

327310 Portland Cement manufacturing plants

K. Ferroalloy 

Production

331112 Ferroalloys manufacturing facilities

L. Fluorinated GHG 

Production

325120 Industrial gases manufacturing facilities

N. Glass Production 327211 Flat glass manufacturing facilities; 327213 

Glass container manufacturing facilities; 327212 Other 

pressed and blown glass and glassware manufacturing 

facilities

O. HCFC-22 

Production and HFC23 Destruction

325120 Chlorodifluoromethane manufacturing facilities

P. Hydrogen 

Production

325120 Hydrogen manufacturing facilities
August 2013 

Part and Subpart NAICS code(s)

Q. Iron and Steel 

Production

331111 Integrated iron and steel mills, steel 

companies, sinter plants, blast furnaces, basic oxygen 

process furnace (BOPF) shops

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

331492 Secondary lead smelting and refining facilities

S. Lime 

Manufacturing

327410 Calcium oxide, calcium hydroxide, dolomitic 

hydrates manufacturing facilities

U. Miscellaneous 

Uses of Carbonate

Facilities included elsewhere

V. Nitric Acid 

Production

325311 Nitric acid manufacturing facilities

W. Petroleum and 

Natural Gas Systems 

1

Pipeline transportation of natural gas, natural gas 

distribution facilities, extractors of crude petroleum 

and natural gas, natural gas liquid extraction 

facilities

X. Petrochemical 

Production

32511 Ethylene dichloride manufacturing facilities; 

325199 Acrylonitrile, ethylene oxide, methanol 

manufacturing facilities; 325110 Ethylene 

manufacturing facilities; 325182 Carbon black 

manufacturing facilities

Y. Petroleum 

Refineries

324110 Petroleum refineries

Z. Phosphoric Acid 

Production

325312 Phosphoric acid manufacturing facilities

AA. Pulp and Paper 

Manufacturing

322110 Pulp mills; 322121 Paper mills; 322130 

Paperboard mills

BB. Silicon Carbide 

Production

327910 Silicon carbide abrasives manufacturing 

facilities

CC. Soda Ash 

Manufacturing

325181 Alkalis and chlorine manufacturing facilities, 

212391 Soda ash, natural, mining and/or beneficiation

EE. Titanium 

Dioxide Production

325188 Titanium dioxide manufacturing facilities

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

dust reclaiming facilities, recovering from scrap 

and/or alloying purchased metals

II. Industrial 

Wastewater 

Treatment 1

322110 Pulp mills; 322121 Paper mills; 322122 

Newsprint mills; 322130 Paperboard mills; 311611 Meat 

processing facilities; 311411 Frozen fruit, juice, and 

vegetable manufacturing facilities; 311421 Fruit and 

vegetable canning facilities; 325193 Ethanol 

manufacturing facilities; 324110 Petroleum refineries

1 The EPA is not proposing amendments related to these categories; however, 

these categories were evaluated in the EPA’s analysis of the potential impact 

from the release of inputs to emission equations for which reporting was 

deferred to March 31, 2015. Refer to Section 1.B of this preamble for further 

discussion of this evaluation.

4(b) Information Requested
August 2013 

(i) Data Items. EPA is proposing that 26 new data elements 

be reported. The following table specifies each new data element

that would be reported, by subpart:

Subpart Subpart Name New Data Element Description

E Adipic Acid 

Production

Annual quantity of cyclohexane fed to all 

production lines (metric tons).

Annual percent N2O emission reduction for all 

production units combined.

G Ammonia 

Production

Annual ammonia production (metric tons).

Annual methanol production (metric tons), if this 

quantity is not reported under subpart X of 40 CFR 

part 98. 

H Cement 

Production

Annual clinker production (metric tons).

Annual average clinker CO2 emission factor for the 

facility, averaged across all kilns (metric tons 

CO2/metric ton clinker produced).

Annual average cement kiln dust (CKD) CO2 emission 

factor for the facility, averaged across all kilns 

(metric tons CO2/metric ton CKD produced).

P Hydrogen 

Production

Name and annual quantity (metric tons) of each 

carbon-containing fuel and feedstock.

Annual methanol production (metric tons), if this 

quantity is not reported under subpart X of 40 CFR 

part 98.

Q Iron and Steel 

Production

If you use the carbon mass balance method in 

§98.173(b)(1) to determine CO2 emissions: The 

annual mass (metric tons) of all gaseous, liquid, 

and solid fuels (combined) used in process units 

specified in Equations Q-1 through Q-7 of 40 CFR 

part 98, calculated as specified in a proposed new 

Equation Q-9 in the proposed rule amendments. Do 

not include fuel used in a stationary combustion 

unit where emissions are reported under subpart C 

of this part.

If you use the carbon mass balance method in 

§98.173(b)(1) to determine CO2 emissions: The 

annual mass (metric tons) of all non-fuel material 

inputs (combined) specified in Equations Q-1 

through Q-7 of 40 CFR part 98, calculated as 

specified in a proposed new Equation Q-10 in the 

proposed rule amendments.

If you use the carbon mass balance method in 

§98.173(b)(1) to determine CO2 emissions: The 

annual mass (metric tons) of all solid and liquid 

products and byproducts (combined) specified in 

Equations Q-1 through Q-7 of 40 CFR part 98, 

calculated as specified in a proposed new Equation 

Q-11 in the proposed rule amendments.
August 2013 

Subpart Subpart Name New Data Element Description

If you use the carbon mass balance method in 

§98.173(b)(1) to determine CO2 emissions: The 

weighted average carbon content of all gaseous, 

liquid, and solid fuels (combined) included in 

proposed new Equation Q-9, calculated as specified 

in a proposed new Equation Q-12 in the proposed 

rule amendments.

If you use the carbon mass balance method in 

§98.173(b)(1) to determine CO2 emissions: The 

weighted average carbon content of all non-fuel 

inputs to all furnaces (combined) included in 

proposed new Equation Q-10, calculated as 

specified in a proposed new Equation Q-13 in the 

proposed rule amendments.

If you use the carbon mass balance method in 

§98.173(b)(1) to determine CO2 emissions: The 

weighted average carbon content of all solid and 

liquid products and byproducts from all furnaces 

(combined) included in a proposed new Equation Q11 in the proposed rule amendments, calculated as 

specified in new Equation Q-14.

S Lime 

Manufacturing

Annual quantity (metric tons) of lime product 

sold, by type.

V Nitric Acid 

Production

Annual percent N2O emission reduction for all 

production units combined.

X Petrochemical 

Production

If using the mass balance method or CEMS method to 

calculate GHG emissions: Name and annual quantity 

(in metric tons) of each carbon-containing 

feedstock.

If using the mass balance method or CEMS method to 

calculate GHG emissions: Name and annual quantity 

(in metric tons) of each carbon-containing coproduct.

Y Petroleum 

Refineries

Annual quantity of flare gas combusted (in MMscf 

per year) (only when using Equation Y-3).

Annual average molecular weight of flare gas 

combusted (in mmBtu per MMscf) (only when using 

Equation Y-3).

Annual average carbon content of flare gas 

combusted (expressed as a decimal fraction)(only 

when using Equation Y-3).

AA Pulp and Paper 

Manufacturing

For each pulp mill lime kiln: Quantity of calcium 

oxide (CaO) produced (metric tons).

For each pulp mill lime kiln: Percent of annual 

heat input, individually for each fossil fuel 

type.

For each chemical recovery furnace and chemical 

recovery combustion unit for which you are not 

using Equation C-2c to calculate CO2 emissions: 

Annual mass of steam generated (lb steam), 

individually for each fossil fuel type and for 

spent liquor solids.

For each chemical recovery furnace and chemical 
August 2013 

Subpart Subpart Name New Data Element Description

recovery combustion unit for which you are not 

using Equation C-2c to calculate CO2 emissions: 

Ratio of the unit’s maximum rated heat input 

capacity to its design rated steam output capacity 

(mmBtu/lb steam), individually for each fossil 

fuel type and for spent liquor solids.

Additionally, for certain “inputs to equations” data 

elements already included in the GHGRP (i.e., already included 

in the information collection request previously approved by OMB

for Part 98), EPA is proposing to change the current 

recordkeeping and reporting methods used by respondents. These 

proposed revisions do not result in a change in the data 

elements entered by respondents into EPA’s e-GGRT system, but 

rather in the way that the data are received and used by the eGGRT system. Refer to section 4(b)(ii) for a discussion of 

changes in this required activity. Refer to section 5(b) for 

more information about EPA’s e-GGRT system. The current 

requirement to maintain records of these data elements in any 

format selected by reporters would be replaced with a 

requirement to maintain an electronic or hard copy of a file 

generated by the inputs verification tool, which lists the data 

elements entered into the tool. For any reporter subject to 

using the inputs verification tool, the retention period for 

maintaining all Part 98 records would be extended from three to 

five years. Refer to section 3(e) for EPA’s justification for 

this revision to the record retention period.

(ii) Respondent Activities. Respondent activities 

associated with each required data element specified in section 

4(b)(i) are identified below. Those respondent activities that 

would result in additional burden are also specified in Table 1 

of Attachment 1.
August 2013 

Reporting Proposed New Data Elements. For each of the 26 

new data elements required to be reported, respondents would be 

required to calculate the data element using readily available 

data, and submit the value via e-GGRT as part of the annual 

report currently required under Part 98.

Training with Proposed Verification Tool. During their 

first session using the proposed inputs verification tool, 

respondents would need to spend time becoming familiar with how 

the tool operates within e-GGRT. The proposed new requirement to 

use the inputs verification tool would not result in any change 

in the respondent activity of entering these data into e-GGRT. 

Respondents would access e-GGRT to enter their data, as 

currently required under the rule. However, “inputs to 

equations” data elements would be entered into a new inputs 

verification tool within e-GGRT and would not be reported to the 

EPA. Refer to section 5(b) for further discussion about the 

tool. The table below specifies the number of “inputs to 

equations” data elements per subpart that respondents would 

enter into the inputs verification tool instead of directly into 

e-GGRT.

Subpart Source Category

Number of “Inputs to Equations” 

Data Elements

Currently 

Required to be 

Reported

Proposed Not to be 

Reported, But 

Instead to be 

Entered into the 

Proposed Inputs 

Verification Tool

C General Stationary Fuel 

Combustion Sources except 

Certain Combustion Units 

Connected to Devices 

Connected to the Local or 

Regional Power Grid 1

262 26

E Adipic Acid Production 21 11

F Aluminum Production 29 29

G Ammonia Manufacturing 8 8

H Cement Production 16 14
August 2013 

Subpart Source Category

Number of “Inputs to Equations” 

Data Elements

Currently 

Required to be 

Reported

Proposed Not to be 

Reported, But 

Instead to be 

Entered into the 

Proposed Inputs 

Verification Tool

K Ferroalloy Production 13 13

L Fluorinated Gas 

Production 55 46

N Glass Production 3 3

O HCFC-22 Production and 

HFC-23 Destruction 15 12

P Hydrogen Production 7 7

Q Iron and Steel 

Production 93 92

R Lead Production 10 10

S Lime Manufacturing (nonCEMS) 9 9

U Miscellaneous Uses of 

Carbonate 6 6

V Nitric Acid Production 21 6

X Petrochemical Production 21 21

Y Petroleum Refineries 80 75

Z Phosphoric Acid 

Production 4 4

AA Pulp and Paper 

Manufacturing 31 28

BB Silicon Carbide 

Production 3 3

CC Soda Ash Manufacturing 10 4

EE Titanium Dioxide 

Production 2 2

GG Zinc Production 8 8

TT Industrial Waste 

Landfills 

3

3

1 The reporting requirements applicable to certain stationary fuel combustion 

sources (e.g., individual units, aggregations of units, common pipes, or 

common stacks) subject to subpart C remain the same under the proposed 

amendment. Subpart C would continue to require reporting of all applicable 

“inputs to equations” data elements for stationary fuel combustion sources

that meet both of the following criteria: (1) the stationary fuel combustion 

source contains at least one combustion unit connected to a fuel-fired 

electric generator that has been granted access by the Public Utilities 

Commission to deliver power to the local or regional electric power grid 

(excluding generators connected to combustion units that are subject to 

subpart D of this part); and (2) the stationary fuel combustion source is 

located at a facility for which the sum of the combined nameplate capacities
August 2013 

for all such electric generators is greater than or equal to 1 megawatt 

electric output. Subpart C reporters would not report “inputs to equations” 

data elements for all other types of stationary fuel combustion sources

subject to subpart C.

2 Includes one “inputs to equations” data element, 40 CFR 98.3(d)(3)(v), 

which is specified in subpart A of part 98 and applies to only certain 

reporters under subpart C of part 98.

Recordkeeping for “Inputs to Equations” Data Elements

Entered into the Inputs Verification Tool. Respondents would be 

required to keep a record of a file generated by the inputs 

verification tool. After completing entry of “inputs to 

equations” data elements into the inputs verification tool, 

respondents would download this file (generated by the inputs 

verification tool) and maintain an electronic or hard copy of 

the file. This new requirement replaces the current requirement 

to maintain records of these data elements in any format 

selected by reporters. As indicated in section 6, this format 

change would not result in any change in respondent burden to 

record these data, as compared to the burden for recording these 

data elements included in the information collection request 

previously approved by OMB.

5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION 

METHODS, AND INFORMATION MANAGEMENT

5(a) Agency Activities

EPA Headquarters activities include the monitoring and 

verification of emission reports, database and software 

maintenance, communication and outreach, and program evaluation.

This ICR reflects an incremental agency burden for program 

operation activities, which include monitoring and verification 

of emission reports. Specifically, the additional burden for the 

review of new data elements for 10 subparts was estimated. 
August 2013 

5(b) Collection Methodology and Management

To collect data currently reported under the GHGRP, EPA 

previously established a central repository of inventory data 

for all respondents, e-GGRT. Respondents report data 

electronically, and EPA stores the data in the database. The eGGRT system has an XML reporting schema that allows facilities 

to upload GHG data directly in lieu of using the web forms 

provided through e-GGRT. Under the proposed revisions to Part 

98, facilities subject to the subparts listed in section 4(a) 

would report the proposed new data elements via e-GGRT. 

Additionally, for verification purposes, they would enter their 

“inputs to equations” data elements into a proposed new inputs 

verification tool embedded within e-GGRT, without reporting 

these data.

The inputs verification tool would be deployed within eGGRT and would be integrated without interrupting the current 

electronic reporting process. Reporters would enter “inputs to 

equations” data elements (that EPA is proposing to remove from 

the reporting requirements) into e-GGRT along with the data 

required to be reported in the annual report. The tool would use 

these entered inputs to emission equations data elements to 

calculate the equation outputs, conduct electronic verification 

checks on the data elements, and generate a verification 

summary. The tool would not retain the entered “inputs to 

equations” data elements for which the EPA is proposing that the 

reporting requirement be removed. Accordingly, the EPA would not 

have access to these “inputs to equations” data elements. 

Instead, the EPA would rely on the verification summary, which 

would become accessible to the EPA when annual reports are 

submitted, as a first step for conducting verification once the 

annual report is submitted.
August 2013 

The new inputs verification tool within e-GGRT follows 

Agency standards for design, security, data element and 

reporting format conformance, and accessibility. EPA designed 

the system in an attempt to minimize respondents’ burden by 

embedding the new inputs verification tool within e-GGRT. 

5(c) Small Entity Flexibility

This information collection will not have a significant 

economic impact on a substantial number of small entities.

Nonetheless, EPA has tried to reduce the impact of this 

information collection on small entities. The EPA supports a 

“help desk” for the GHGRP, which would be available to answer 

questions on the provisions in this rulemaking.

5(d) Collection Schedule

All data elements under this information collection would 

be submitted on an annual basis as part of the respondent’s 

annual report required under Part 98. 

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

This section presents EPA’s estimates of the burden and 

costs to respondents associated with the activities described in 

section 4 as well as the federal burden hours and costs 

associated with the activities described in section 5(a).

Section 6(a) provides estimates of burden (hours) for all 

respondent types. Section 6(b) contains estimates of respondent 

costs for the information collection. Section 6(c) summarizes 

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

universe and the total burden and cost of this collection to 

respondents. Section 6(e) presents the bottom line burden and 

cost. Section 6(f) provides reasons for any change in burden. 
August 2013 

The burden statement for this information collection is in 

section 6(g). 

6(a) Estimating Respondent Burden

EPA estimates the labor hours for the first-year activity 

of training to use the proposed inputs verification tool to be 

1.2 hour per applicable respondent. EPA estimates the labor 

hours for the annual activity of reporting of new data elements

to average 1.8 hour per applicable respondent. Tables 1 through 

3 in Attachment 1 present an itemized breakdown of the reporting 

requirements for the respondents, according to activity and 

sector.

6(b) Estimating Respondent Costs

All costs to the regulated industry resulting from 

information collection activities for the proposed GHGRP are 

labor costs (i.e., the cost of labor by facility staff to meet 

the rule’s information collection requirements). To calculate 

labor costs, EPA estimated Bureau of Labor Statistics using an 

approach consistent with the ICRs associated with the GHGRP 

currently approved by OMB.

4 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.

For the one-time activity of training to use the 

verification tool, EPA estimates the cost per applicable 

respondent to be $66. For the annual activity of reporting the 

proposed new data elements, EPA estimates the average annual 

cost per applicable respondent to be $103. EPA estimates that 

the annual average cost to all respondents to be $206,713 for 

 

4 May 2011 National Industry-Specific Occupational Employment and Wage Estimates 

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

(http://www.bls.gov/news.release/archives/ecec_09082011.pdf).
August 2013 

each of the three years covered by this information collection. 

Respondent costs by sector and activity are presented in 

Attachment 1.

6(c) Estimating Agency Burden and Cost

This section describes the burden and cost to the federal

government associated with this information collection, and the 

details are provided in Attachment 2. For the proposed rule, the 

incremental burden to EPA is associated with the additional time 

to review the new data elements that would be reported (see 

section 4(b)(i)). 

Note that “inputs to equations” data elements will not be 

reported for multiple subparts and a reduction in EPA costs 

could be estimated. However, no costs were subtracted from the 

burden estimate because the verification summaries will still 

allow EPA to verify the data. Additionally, there is no 

certainty that the amount of verification of data will be any 

less, and additional verification items may be incorporated. 

The average annual Agency cost during the three years of 

the ICR is estimated to be $15,000.

This cost is based on the average hourly labor rate as 

follows:

 Managerial $62.27 (GS-13, Step 5, $38.92 + 

60%) 

 Technical $46.21 (GS-12, Step 1, $28.88 + 

60%)

 Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management 

(OPM), 2011 General Schedule, which excludes locality rates of 

pay. The rates have been increased by 60% to account for the 

benefit packages available to government employees.
August 2013 

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

Costs

EPA estimates that 5,736 respondents will complete the onetime activity of training to use the verification tool, and that 

the burden and costs for such respondents over the three years 

covered by this information collection are 6,596 hours and 

$379,244. EPA estimates that 781 respondents per year will 

complete the annual activity of reporting the proposed new data 

elements, and that the burden and costs for such respondents 

over the three years covered by this information collection are 

4,190 hours and $240,895. Based on these estimates, the total 

burden and costs for all respondents over the three years 

covered by this information collection would be 10,786 hours and 

$620,140.

6(e) Bottom Line Burden Hours and Costs

(i) Respondent Tally. A breakdown for each of the proposed 

collection, reporting, and recordkeeping activities is presented 

in Attachment 1. EPA estimates the average annual respondent 

burden and cost over the three years of this information 

collection to be 2,199 labor hours at a cost of $189,622 per 

year for the one-time activity of training to use the 

verification tool and 1,397 labor hours at a cost of $80,298 per 

year for the annual activity of reporting the proposed new data 

elements. Based on these estimates, the average annual 

respondent burden and cost over the three years of this 

information collection would be 3,595 labor hours at a cost of 

$206,713 per year.

(ii) The Agency Tally. The bottom line Agency burden hours 

and costs are presented in Attachment 2. The average annual 
August 2013 

Agency burden and cost over the three years of this information 

collection would be 330 labor hours at a cost of $15,000.

6(f) Reasons for Change in Burden

The overall reporting for Part 98 would increase slightly

due to these proposed revisions to Part 98. Refer to section 4 

for a summary of the proposed new data elements and respondent 

activities that would increase the respondent burden. EPA 

estimates the increase in burden for all respondents to be 

10,786 hours over the first three years of this information 

collection request, consisting of 6,596 hours for the first-year 

activity of learning new procedures for the verification tool

and 4,190 hours for the annual activity of reporting of new data 

elements. Refer to section 6(a) for further discussion of the 

increase to respondent burden.

6(g) Burden Statement

Attachment 1 presents the average annual respondent burden 

for each sector and activity. For the 5,736 respondents subject 

to the 24 subparts required to report “inputs to emission 

equations” data elements, EPA estimates the public reporting 

burden for learning new procedures for the inputs verification 

tool to be 1.2 hours per respondent for only the first year of 

the 3-year information collection period. For all such 

respondents, the average annual respondent burden over the 3-

year collection of information period is estimated to be 2,199

hours, or 0.4 hours per respondent.

For the 781 respondents subject to subparts E, G, H, P, Q, 

S, V, X, Y, and AA, EPA estimates the public burden for 

reporting new data elements to average 1.8 hour per respondent

per year. This estimate includes the time to gather available 

data, calculate the new data element, and enter the data element 
August 2013 

into e-GGRT. For all such respondents, the average annual 

respondent burden over the 3-year collection of information 

period is estimated to be 1,397 hours. 

For all respondents, the average annual respondent burden 

over the 3-year collection of information period is estimated to 

be 3,595 hours. The average annual burden to EPA for this period

is estimated to be 330 hours for oversight activities.

Burden means the total time, effort, or financial resources 

expended by persons to generate, maintain, retain, or disclose 

or provide information to or for a federal agency. This includes 

the time needed to review instructions; develop, acquire, 

install, and utilize technology and systems for the purposes of 

collecting, validating, and verifying information, processing 

and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any 

previously applicable instructions and requirements; train 

personnel to respond to a collection of information; search data 

sources; complete and review the collection of information; and 

transmit or otherwise disclose the information.

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

required to respond to, a collection of information unless it 

displays a currently valid OMB control number. The OMB control 

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

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

accuracy of the provided burden estimates, and any suggested 

methods for minimizing respondent burden, including the use of 

automated collection techniques, EPA has established a public 

docket for this ICR under Docket ID Number EPA–HQ–OAR–2010-0929, 

which is available for online viewing at 

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

Radiation docket in the EPA Docket Center (EPA/DC), William 

Jefferson Clinton Federal Building - West, Room 3334, 1301 
August 2013 

Constitution Avenue, NW, Washington, D.C. The EPA Docket Center 

Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday 

through Friday, excluding legal holidays. The telephone number 

for the Reading Room is (202) 566-1744, and the telephone number 

for the Air and Radiation docket is (202) 566-1742. An 

electronic version of the public docket is available at 

http://www.regulations.gov. This site can be used to submit or 

view public comments, access the index listing of the contents 

of the public docket, and to access those documents in the 

public docket that are available electronically. When in the 

system, select “search,” then key in the Docket ID Number 

identified above. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: 

Desk Officer for EPA. Please include the EPA Docket ID Number 

EPA–HQ–OAR–2010-0929and OMB Control Number 2060-0629 on any 

correspondence.
ATTACHMENT 1

TABLES 1, 2, 3, and 4

Tables 1 - 3: Annual Respondent Burden and Cost of 

Recordkeeping and Reporting Requirements for Revisions 

to Reporting, Recordkeeping, and Verification 

Requirements under the Greenhouse Gas Reporting 

Program - Years 1-3

Table 4: Summary of Annual Respondent Burden and Cost of 

Recordkeeping and Reporting Requirements for Revisions 

to Reporting, Recordkeeping, and Verification 

Requirements under the Greenhouse Gas Reporting 

Program
C E F G H K L N O P Q R S U V X Y Z AA BB CC EE GG TT

1. REPORTING REQUIREMENTS

a. Initial Training with Inputs Verification Tool (a)

 i. Number of Respondents Per Year (b) 5736 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 ii. Number of Occurences Per Respondent Year 

(first year only) (d) 1 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

i. Technical Respondent Hours Per Occurrence 1 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

b. Annual Reporting of New Data Elements (e)

 i. Number of Respondents per Year (b) 781 0 3 0 22 98 0 0 0 0 103 128 0 73 0 35 64 145 0 110 0 0 0 0 0

 iii. Number of New Data Elements (f) 26 0 2 0 2 3 0 0 0 0 2 6 0 1 0 1 2 3 0 4 0 0 0 0 0

 iii. Number of Occurrences Per Respondent Per 

Year (d) 1 0 1 0 1 1 0 0 0 0 1 1 0 1 0 1 1 1 0 1 0 0 0 0 0

iv. Technical Respondent Hours Per Occurrence 

(g) varies 0 1 0 1 1.5 0 0 0 0 1 3 0 0.5 0 0.5 1 1.5 0 2 0 0 0 0 0

2. SUBTOTAL COST AND HOURS FOR BURDEN ITEM GROUPS

a. Respondent Hours

 i. Technical 5,736 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 ii. Clerical (h) 574 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 iiii. Managerial (h) 287 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 iv. Total 6,596 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

b. Respondent Costs

 i. Technical (i) $339,112 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 ii. Clerical (i) $17,982 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 iiii. Managerial (i) $22,150 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 iv. Total $379,244 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

a. Respondent Hours

 i. Technical 1,215 0 3 0 22 147 0 0 0 0 103 384 0 37 0 18 64 218 0 220 0 0 0 0 0

 ii. Clerical (h) 121 0 0 0 2 15 0 0 0 0 10 38 0 4 0 2 6 22 0 22 0 0 0 0 0

 iiii. Managerial (h) 61 0 0 0 1 7 0 0 0 0 5 19 0 2 0 1 3 11 0 11 0 0 0 0 0

 iv. Total 1,397 0 3 0 25 169 0 0 0 0 118 442 0 42 0 20 74 250 0 253 0 0 0 0 0

b. Respondent Costs

 i. Technical (i) $71,801 $0 $177 $0 $1,301 $8,691 $0 $0 $0 $0 $6,089 $22,702 $0 $2,158 $0 $1,035 $3,784 $12,859 $0 $13,006 $0 $0 $0 $0 $0

 ii. Clerical (i) $3,807 $0 $9 $0 $69 $461 $0 $0 $0 $0 $323 $1,204 $0 $114 $0 $55 $201 $682 $0 $690 $0 $0 $0 $0 $0

 iiii. Managerial (i) $4,690 $0 $12 $0 $85 $568 $0 $0 $0 $0 $398 $1,483 $0 $141 $0 $68 $247 $840 $0 $850 $0 $0 $0 $0 $0

 iv. Total $80,298 0 198 0 1,455 9,719 0 0 0 0 6,810 25,389 0 2,413 0 1,157 4,231 14,380 0 14,546 0 0 0 0 0

3. TOTAL COST AND HOURS FOR ALL BURDEN ITEMS

ANNUAL LABOR HOURS:

Technical 6,951

Clerical 695

Managerial 348

Total Hours 7,993

ANNUAL COST:

Technical $410,914

Clerical $21,790

Managerial $26,839

Total Cost $459,543

FOOTNOTES

a. This line item accounts for time to train and understand the proposed inputs verification tool.

d. Assumed that time spent on each reporting burden item would occur only once per year, because items are annual values and/or because related items were already tracked. For training to use the inputs verification tool, time would be spent once per year for the initial year only.

e. Reporting time associated with new data elements.

f. New data elements for each subpart are specified in Table 4 of the preamble and in section 4(b)(i) of the supporting statement.

g. Assume that reporting will require 30 technical labor minutes per new data elemnet.

i. Assume technical labor cost of $59.12/hour; clerical labor cost of $31.35/hour ; and managerial labor cost of $77.23/hour.

h. Managerial Hours = (Technical Hours * .05) and Clerical Hours = (Technical Hours * 0.1)

b. The count of the number of subparts subject to using the inputs verification tool and subject to reporting new data elements are based on the actual counts of 2011 GHGRP reporters (Feb 2013 update). 

Table 1. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for Revisions to Reporting, Recordkeeping, and Verification Requirements under the Greenhouse Gas Reporting Program - 

Year 1 (2014)

Subpart All Affected 

Subparts Burden Item

Initial Training with Inputs Verification Tool and Annual Recording of Data Entered into Tool

Annual Reporting of New Data Elements

c. Due to respondents being subject to multiple subparts (e.g., paper mills subject to subparts C, AA, and TT), the burden is not shown per industrial sector/subpart. The total count of respondents subject to using the proposed inputs verification tool does not double-count 

facilities subject to multiple subparts. Irregardless of the number of subparts to which a respondent is subject, the respondent would need to perform training for the tool only once. 
C E F G H K L N O P Q R S U V X Y Z AA BB CC EE GG TT

1. REPORTING REQUIREMENTS

a. Initial Training with Inputs Verification Tool (a)

 i. Number of Respondents Per Year (b) 0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 ii. Number of Occurences Per 

Respondent Year (first year only) (d) 0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

i. Technical Respondent Hours Per 

Occurrence 1 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

b. Annual Reporting of New Data Elements (e)

 i. Number of Respondents per Year (b) 781 0 3 0 22 98 0 0 0 0 103 128 0 73 0 35 64 145 0 110 0 0 0 0 0

 iii. Number of New Data Elements (f) 26 0 2 0 2 3 0 0 0 0 2 6 0 1 0 1 2 3 0 4 0 0 0 0 0

 iii. Number of Occurrences Per 

Respondent Per Year (d) 1 0 1 0 1 1 0 0 0 0 1 1 0 1 0 1 1 1 0 1 0 0 0 0 0

iv. Technical Respondent Hours Per 

Occurrence (g) varies 0 1 0 1 1.5 0 0 0 0 1 3 0 0.5 0 0.5 1 1.5 0 2 0 0 0 0 0

2. SUBTOTAL COST AND HOURS FOR BURDEN ITEM GROUPS

a. Respondent Hours

 i. Technical 0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 ii. Clerical (h) 0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 iiii. Managerial (h) 0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 iv. Total 0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

b. Respondent Costs

 i. Technical (i) $0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 ii. Clerical (i) $0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 iiii. Managerial (i) $0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 iv. Total $0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

a. Respondent Hours

 i. Technical 1,215 0 3 0 22 147 0 0 0 0 103 384 0 37 0 18 64 218 0 220 0 0 0 0 0

 ii. Clerical (h) 121 0 0 0 2 15 0 0 0 0 10 38 0 4 0 2 6 22 0 22 0 0 0 0 0

 iiii. Managerial (h) 61 0 0 0 1 7 0 0 0 0 5 19 0 2 0 1 3 11 0 11 0 0 0 0 0

 iv. Total 1,397 0 3 0 25 169 0 0 0 0 118 442 0 42 0 20 74 250 0 253 0 0 0 0 0

b. Respondent Costs

 i. Technical (i) $71,801 $0 $177 $0 $1,301 $8,691 $0 $0 $0 $0 $6,089 $22,702 $0 $2,158 $0 $1,035 $3,784 $12,859 $0 $13,006 $0 $0 $0 $0 $0

 ii. Clerical (i) $3,807 $0 $9 $0 $69 $461 $0 $0 $0 $0 $323 $1,204 $0 $114 $0 $55 $201 $682 $0 $690 $0 $0 $0 $0 $0

 iiii. Managerial (i) $4,690 $0 $12 $0 $85 $568 $0 $0 $0 $0 $398 $1,483 $0 $141 $0 $68 $247 $840 $0 $850 $0 $0 $0 $0 $0

 iv. Total $80,298 0 198 0 1,455 9,719 0 0 0 0 6,810 25,389 0 2,413 0 1,157 4,231 14,380 0 14,546 0 0 0 0 0

3. TOTAL COST AND HOURS FOR ALL BURDEN ITEMS

ANNUAL LABOR HOURS:

Technical 1,215

Clerical 121

Managerial 61

Total Hours 1,397

ANNUAL COST:

Technical $71,801

Clerical $3,807

Managerial $4,690

Total Cost $80,298

FOOTNOTES

a. This line item accounts for time to train and understand the proposed inputs verification tool.

d. Assumed that time spent on each reporting burden item would occur only once per year, because items are annual values and/or because related items were already tracked. For training to use the inputs verification tool, time would be spent once per year for the initial year only.

e. Reporting time associated with new data elements.

f. New data elements for each subpart are specified in Table 4 of the preamble and in section 4(b)(i) of the supporting statement.

g. Assume that reporting will require 30 technical labor minutes per new data elemnet.

i. Assume technical labor cost of $59.12/hour; clerical labor cost of $31.35/hour ; and managerial labor cost of $77.23/hour.

Table 2. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for Revisions to Reporting, Recordkeeping, and Verification Requirements under the Greenhouse Gas Reporting 

Program - Year 2 (2015)

Burden Item All Affected 

Subparts

Subpart

h. Managerial Hours = (Technical Hours * .05) and Clerical Hours = (Technical Hours * 0.1)

Initial Training with Inputs Verification Tool and Annual Recording of Data Entered into Tool

Annual Reporting of New Data Elements

b. The count of the number of subparts subject to using the inputs verification tool and subject to reporting new data elements are based on the actual counts of 2011 GHGRP reporters (Feb 2013 update). 

c. Due to respondents being subject to multiple subparts (e.g., paper mills subject to subparts C, AA, and TT), the burden is not shown per industrial sector/subpart. The total count of respondents subject to using the proposed inputs verification tool 

does not double-count facilities subject to multiple subparts. Irregardless of the number of subparts to which a respondent is subject, the respondent would need to perform training for the tool only once. 
C E F G H K L N O P Q R S U V X Y Z AA BB CC EE GG TT

1. REPORTING REQUIREMENTS

a. Initial Training with Inputs Verification Tool (a)

 i. Number of Respondents Per Year (b) 0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 ii. Number of Occurences Per 

Respondent Year (first year only) (d) 0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

i. Technical Respondent Hours Per 

Occurrence 1 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

b. Annual Reporting of New Data Elements (e)

 i. Number of Respondents per Year (b) 781 0 3 0 22 98 0 0 0 0 103 128 0 73 0 35 64 145 0 110 0 0 0 0 0

 iii. Number of New Data Elements (f) 26 0 2 0 2 3 0 0 0 0 2 6 0 1 0 1 2 3 0 4 0 0 0 0 0

 iii. Number of Occurrences Per 

Respondent Per Year (d) 1 0 1 0 1 1 0 0 0 0 1 1 0 1 0 1 1 1 0 1 0 0 0 0 0

iv. Technical Respondent Hours Per 

Occurrence (g) varies 0 1 0 1 1.5 0 0 0 0 1 3 0 0.5 0 0.5 1 1.5 0 2 0 0 0 0 0

2. SUBTOTAL COST AND HOURS FOR BURDEN ITEM GROUPS

a. Respondent Hours

 i. Technical 0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 ii. Clerical (h) 0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 iiii. Managerial (h) 0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 iv. Total 0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

b. Respondent Costs

 i. Technical (i) $0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 ii. Clerical (i) $0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 iiii. Managerial (i) $0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

 iv. Total $0 (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c) (c)

a. Respondent Hours

 i. Technical 1,215 0 3 0 22 147 0 0 0 0 103 384 0 37 0 18 64 218 0 220 0 0 0 0 0

 ii. Clerical (h) 121 0 0 0 2 15 0 0 0 0 10 38 0 4 0 2 6 22 0 22 0 0 0 0 0

 iiii. Managerial (h) 61 0 0 0 1 7 0 0 0 0 5 19 0 2 0 1 3 11 0 11 0 0 0 0 0

 iv. Total 1,397 0 3 0 25 169 0 0 0 0 118 442 0 42 0 20 74 250 0 253 0 0 0 0 0

b. Respondent Costs

 i. Technical (i) $71,801 $0 $177 $0 $1,301 $8,691 $0 $0 $0 $0 $6,089 $22,702 $0 $2,158 $0 $1,035 $3,784 $12,859 $0 $13,006 $0 $0 $0 $0 $0

 ii. Clerical (i) $3,807 $0 $9 $0 $69 $461 $0 $0 $0 $0 $323 $1,204 $0 $114 $0 $55 $201 $682 $0 $690 $0 $0 $0 $0 $0

 iiii. Managerial (i) $4,690 $0 $12 $0 $85 $568 $0 $0 $0 $0 $398 $1,483 $0 $141 $0 $68 $247 $840 $0 $850 $0 $0 $0 $0 $0

 iv. Total $80,298 0 198 0 1,455 9,719 0 0 0 0 6,810 25,389 0 2,413 0 1,157 4,231 14,380 0 14,546 0 0 0 0 0

3. TOTAL COST AND HOURS FOR ALL BURDEN ITEMS

ANNUAL LABOR HOURS:

Technical 1,215

Clerical 121

Managerial 61

Total Hours 1,397

ANNUAL COST:

Technical $71,801

Clerical $3,807

Managerial $4,690

Total Cost $80,298

FOOTNOTES

a. This line item accounts for time to train and understand the proposed inputs verification tool.

d. Assumed that time spent on each reporting burden item would occur only once per year, because items are annual values and/or because related items were already tracked. For training to use the inputs verification tool, time would be spent once per year for the initial year only.

e. Reporting time associated with new data elements.

f. New data elements for each subpart are specified in Table 4 of the preamble and in section 4(b)(i) of the supporting statement.

g. Assume that reporting will require 30 technical labor minutes per new data elemnet.

i. Assume technical labor cost of $59.12/hour; clerical labor cost of $31.35/hour ; and managerial labor cost of $77.23/hour.

Table 3. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for Revisions to Reporting, Recordkeeping, and Verification Requirements under the Greenhouse Gas Reporting Program 

- Year 3 (2016)

Burden Item All Affected 

Subparts

Subpart

h. Managerial Hours = (Technical Hours * .05) and Clerical Hours = (Technical Hours * 0.1)

Initial Training with Inputs Verification Tool and Annual Recording of Data Entered into Tool

Annual Reporting of New Data Elements

b. The count of the number of subparts subject to using the inputs verification tool and subject to reporting new data elements are based on the actual counts of 2011 GHGRP reporters (Feb 2013 update). 

c. Due to respondents being subject to multiple subparts (e.g., paper mills subject to subparts C, AA, and TT), the burden is not shown per industrial sector/subpart. The total count of respondents subject to using the proposed inputs verification tool does not 

double-count facilities subject to multiple subparts. Irregardless of the number of subparts to which a respondent is subject, the respondent would need to perform training for the tool only once. 
Year Number of 

Responses

Total Labor 

Hours Labor Costs

Non-Labor Costs 

(Annualized Capital/Startup 

and O&M)

Total Costs

1 6517 7,993 $459,543 $0 $459,543

2 781 1,397 $80,298 $0 $80,298

3 781 1,397 $80,298 $0 $80,298

Total 8,079 10,786 $620,140 $0 $620,140

Average 2,693 3,595 $206,713 $0 $206,713

Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements 

for Revisions to Reporting, Recordkeeping, and Verification Requirements under the Greenhouse Gas 

Reporting Program
ATTACHMENT 2

TABLES 5, 6, 7, and 8

Tables 5 - 7: Annual Designated Administrator Burden and Cost 

of Recordkeeping and Reporting Requirements for 

Revisions to Reporting, Recordkeeping, and 

Verification Requirements under the Greenhouse Gas 

Reporting Program - Years 1-3

Table 8: Summary of Annual Designated Administrator Burden and 

Cost of Recordkeeping and Reporting Requirements for 

Revisions to Reporting, Recordkeeping, and 

Verification Requirements under the Greenhouse Gas 

Reporting Program
(A) (B) (C) (D) (E) (F)

Number of 

Occurrences Per 

Year

EPA Hours Per 

Occurrence

Tech Hours 

Per Year 

(C=AxB)

Management 

Hours Per Year 

(D=Cx0.05)

Clerical 

Hours Per 

Year 

(E=Cx0.1)

EPA Cost 

Per Year 

(a,b)

1. Applications

2. Read and Understand Rule Requirements 60 2 120 6 12 $6,219 a

3. Required Activities

A.

B. Excess emissions -- Enforcement Activities

C. Create Information

D. Gather Information

E. Report Reviews

1. Review new data elements 2429 0.1 243 12 24 $12,588 b

F. Prepare annual summary report

4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) = $0 per trip $0

TOTAL 363 18 36 $18,806

FOOTNOTES

a Number of occurences is the number of states where affected sources will exist and each EPA Region (50 states + 10 EPA regions = 60 respondents).

b Number of occurrences is the number of new data elements to be reported times the facility count for each applicable subpart with new data elements

not applicable

Table 5 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements for Revisions to Reporting, 

Recordkeeping, and Verification Requirements under the Greenhouse Gas Reporting Program - Year 1 (2014)

Footnotes

Burden Item

not applicable

Observe stack tests

not applicable

not applicable

not applicable

not applicable
(A) (B) (C) (D) (E) (F)

Number of 

Occurrences Per 

Year

EPA Hours Per 

Occurrence

Tech Hours 

Per Year 

(C=AxB)

Management 

Hours Per Year 

(D=Cx0.05)

Clerical 

Hours Per 

Year 

(E=Cx0.1)

EPA Cost 

Per Year 

(a,b)

1. Applications

2. Read and Understand Rule Requirements 0 2 0 0 0 $0 a

3. Required Activities

A.

B. Excess emissions -- Enforcement Activities

C. Create Information

D. Gather Information

E. Report Reviews

1. Review new data elements 2429 0.1 243 12 24 $12,588 b

F. Prepare annual summary report

4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) = $0 per trip $0

TOTAL 243 12 24 $12,588

FOOTNOTES

a Number of occurences is the number of states where affected sources will exist and each EPA Region (50 states + 10 EPA regions = 60 respondents).

b Number of occurrences is the number of new data elements to be reported times the facility count for each applicable subpart with new data elements

Observe stack tests not applicable

Table 6 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements for Revisions to Reporting, 

Recordkeeping, and Verification Requirements under the Greenhouse Gas Reporting Program - Year 2 (2015)

Footnotes

Burden Item

not applicable

not applicable

not applicable

not applicable

not applicable
(A) (B) (C) (D) (E) (F)

Number of 

Occurrences Per 

Year

EPA Hours Per 

Occurrence

Tech Hours 

Per Year 

(C=AxB)

Management 

Hours Per Year 

(D=Cx0.05)

Clerical 

Hours Per 

Year 

(E=Cx0.1)

EPA Cost 

Per Year 

(a,b)

1. Applications

2. Read and Understand Rule Requirements 0 2 0 0 0 $0 a

3. Required Activities

A.

B. Excess emissions -- Enforcement Activities

C. Create Information

D. Gather Information

E. Report Reviews

1. Review new data elements 2429 0.1 243 12 24 $12,588 b

F. Prepare annual summary report

4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) = $0 per trip $0

TOTAL 243 12 24 $12,588

FOOTNOTES

a Number of occurences is the number of states where affected sources will exist and each EPA Region (50 states + 10 EPA regions = 60 respondents).

b Number of occurrences is the number of new data elements to be reported times the facility count for each applicable subpart with new data elements

Observe stack tests not applicable

Table 7 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements for Revisions to Reporting, 

Recordkeeping, and Verification Requirements under the Greenhouse Gas Reporting Program - Year 3 (2016)

Footnotes

Burden Item

not applicable

not applicable

not applicable

not applicable

not applicable
Year Technical 

Hours

Management 

Hours

Clerical 

Hours Total Hours Labor Costs Non-Labor Costs Total Costs

1 363 18 36 417 $18,806 $0 $18,806

2 243 12 24 279 $12,588 $0 $12,588

3 243 12 24 279 $12,588 $0 $12,588

Total 849 42 85 976 $43,982 $0 $43,982

Average 283 14 28 325 $14,661 $0 $14,661

Table 8 - Summary of Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements 

for Revisions to Reporting, Recordkeeping, and Verification Requirements under the Greenhouse Gas Reporting 

Program