1

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Revisions to Reporting and Recordkeeping Requirements, and 

Final Confidentiality Determinations Under the Greenhouse Gas 

Reporting Program

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection

Revisions to Reporting and Recordkeeping Requirements, and 

Final Confidentiality Determinations Under the Greenhouse Gas 

Reporting Program; OMB control number 2060-0629; ICR number 

2300.12.

1(b) Short Characterization/Abstract

This supporting statement addresses information collection 

activities that will be imposed by revisions to the greenhouse 

gas reporting rule (40 CFR part 98; henceforth referred to as 

Part 98), finalized by the 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 revisions address how the 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, the EPA deferred reporting of these data 
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elements (see August 25, 2011 final action, 76 FR 53057) to 

allow the 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, the EPA proposed

amendments to reporting and recordkeeping requirements for 

reporters subject to the 24 subparts for which reporting of

these inputs to emission equations was deferred to 2015 (see 

September 11, 2013 proposed action, 78 FR 55994). In this 

action, the EPA is finalizing the revisions to the reporting and 

recordkeeping requirements for reporters subject to these 23

subparts. These revisions include:

 For reporters subject to 23 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 certain “inputs to 

equations” data elements via the web-based Electronic 

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

 

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 For subpart C, stationary fuel combustion sources (e.g., individual units, 

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

the final amendments if they contain at least one combustion unit connected 

to a fuel-fired electric generator owned or operated by an entity that is 

subject to regulation of customer billing rates by the public utility 

commission (PUC) (excluding generators connected to combustion units subject 

to 40 CFR part 98, subpart D) and that are 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. All other subpart C 

sources may elect to report inputs to emission equations rather than use the 

inputs verification tool. If these sources elect to report inputs to 

equations, they are not affected by the final amendments.
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these data into e-GGRT), and, instead, requiring that 

these equation inputs be entered into an inputs 

verification tool3 provided in e-GGRT. The amendments

will 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 21 new data elements.

 For subpart W, delaying reporting of six inputs to 

equations related to specific types of exploratory wells 

for two years due to disclosure concerns identified with 

early public disclosure. The EPA determined there was no 

burden associated with these provisions.

These activities will enable the 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 information collection will increase the estimated 

respondent burden by 9,528 hours and $547,775. This increase 

reflects the additional costs incurred for: (1) 5,795

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

 

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

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

otherwise accessible) to EPA. The tool will use entered data to conduct 

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 will be kept on-site as a 

record by reporters. Refer to section 5(b) for further discussion of the 

tool. 
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inputs verification tool and (2) 592 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 finalizing 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 

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

the information to be gathered by Part 98 because such data will

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

of CAA provisions. Additionally, signed into law on December 26, 

2007, the FY2008 Consolidated Appropriations Act directed the 

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 the 

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 
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Administrator may reasonably require. Because the 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 

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. The EPA’s online data 

publication tool allows users to view and sort GHG data for 

calendar year 2012 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 is 

expected to significantly improve our understanding of key 

emissions sources. GHGRP data have already been used to update 

emissions estimates for certain sources in the US GHG Inventory, 

and EPA continues to assess the GHGRP data for further updates 

to the USGHG Inventory.

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.
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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 

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 the EPA to gain a better understanding of the entire CO2

capture and sequestration (CCS) system.

Information collected from fluorocarbons allows the 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. The EPA 
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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 to be collected under the revisions are 

21 new data elements affecting 9 subparts of Part 98 (refer to 

section 4(b) for a list of these data elements). These new data 

elements consist 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 will provide key information for 

verification, including confirming that emissions are 

appropriate for a given activity-level and estimating expected 

emissions based on data provided. These new reporting elements, 

described above, are the same types of industry data currently

collected under the GHGRP. The 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 new data elements as well.

In developing the GHGRP, the 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, 
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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 

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. 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, the EPA has made significant efforts to facilitate the 

reporting in the event a single entity has to report both the 

federal and state level. For example, the 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 the EPA’s GHGRP. The product of the 

collaboration is referred to as California Electronic Greenhouse 

Gas Reporting Tool, or Cal e-GGRT.

Documentation of the EPA’s review of GHG monitoring 

protocols used by federal and state voluntary and mandatory GHG 
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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:

 A number of the 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 the EPA learn more 

about emissions from facilities not included in current 

programs.

 The 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. Data collected through GHGRP is 

expected to significantly improve our understanding of 

key emissions sources. GHGRP data have already been used 

to update emissions estimates for certain sources in the 

US GHG Inventory, and EPA continues to assess the GHGRP 

data for further updates to the USGHG Inventory.

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
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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 final rulemaking for the Revisions to 

Reporting and Recordkeeping Requirements, and 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, the EPA deferred reporting of these 

data elements to allow the 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 completed its evaluation 

of the potential impact, the EPA proposed the amendments to 

address this issue, while allowing the EPA to verify emissions

and ensure compliance with the program. The EPA provided the 

public the opportunity to comment on the proposed amendments. As 
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a result of comments received, the EPA decided to reduce the 

number of new reporting requirements added to the rule from 26 

to 21, thereby reducing the estimated burden of the final rule. 

Several commenters objected to the proposed extension of the 

recordkeeping retention period from 3 years to 5 years. However, 

no information was submitted by commenters that would allow the 

EPA to re-analyze the burden of the extended recordkeeping 

requirement or re-evaluate the EPA’s rationale for needing the 

additional time for record retention. Our rationale is briefly 

presented in section 3(e) and in detail in Section II.C.3 of the 

preamble to the final rule. Therefore, the EPA is finalizing the 

amendment to require record retention for 5 years for facilities 

required to use the inputs verification tool. In addition, the 

EPA is delaying reporting of six inputs to equations related to 

specific types of exploratory wells for subpart W for two years 

as a result of comments. The two year delay was determined to be 

sufficient to prevent early public disclosure of potentially 

sensitive information regarding certain types of exploratory 

wells.

The comments and the EPA’s responses are contained in the 

document “Response to Public Comments on the Revisions to 

Reporting and Recordkeeping Requirements, and Proposed 

Confidentiality Determinations Under the Greenhouse Gas 

Reporting Program” in Docket ID No. EPA-HQ-OAR-2010-0929.

3(d) Effects of Less Frequent Collection

The frequency for reporting emissions information to the 

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 

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

requires annual reporting, except for a limited number of 
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facilities that are already subject to more frequent reporting 

requirements. This reporting frequency remains the same in these 

revisions to Part 98.

Annual reporting will ensure that data are verified and 

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

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

the information collection were not carried out on this 

schedule, the Agency will 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 will be exceeded,

with the exception of requiring records to be maintained for 

more than three years. The EPA is requiring that reporters using

the inputs verification tool retain records for five years. 

Given the verification approach described in Section 1(b), the 

EPA considered whether the current record retention period and 

record format requirements will be sufficient to allow the EPA 

to perform data verification. We considered:

 The time we will 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 will

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) will allow an EPA 

inspector to efficiently analyze the consistency of the 

data elements and use the data elements to perform 

calculations to confirm reported GHG emissions.
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Because there may be more direct follow-up activities under 

this alternative verification approach, we are extending 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 is important that relevant records are available 

to the EPA for follow-up activities with facilities, including 

on-site visits if necessary, regarding potential errors, 

discrepancies, or questions. Should an EPA employee visit a 

facility, it is important to be able to examine not only the 

current year’s records but those from previous years as well, 

because previous years’ data will provide year-to-year 

comparisons, which are useful for verifying the current year’s 

data. A 5-year record retention period ensures 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, the 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, the EPA previously 

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

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

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

published CBI determinations for most information reported under 

the GHGRP (May 26, 2011, 76 FR 30782; August 13, 2012, 77 FR 
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48072; August 24, 2012, 77 FR 51477; November 13, 2013, 78 FR 

68162; November 29, 2013 78 FR 71904; and in this 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 

the 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 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, the 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 revisions to Part 98 affect facilities subject to the 

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

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
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Part and Subpart NAICS code(s)

U. Miscellaneous 

Uses of Carbonate

Facilities included elsewhere

V. Nitric Acid 

Production

325311 Nitric acid manufacturing facilities

W. Petroleum and 

Natural Gas Systems 

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 making amendments related to this source category; 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. 

4(b) Information Requested

(i) Data Items. The EPA is finalizing amendments that 

require 21 new data elements to be reported. The following table 

specifies each new data element that will be reported, by

subpart:

Subpart Subpart Name New Data Element Description

E Adipic Acid 

Production

If only cyclohexane is oxidized to produce adipic 

acid: the annual quantity of cyclohexane (tons) 
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Subpart Subpart Name New Data Element Description

used to produce adipic acid. If materials other 

than cyclohexane are oxidized to produce adipic 

acid: the annual quantity of cyclohexanone and

cyclohexanol mixture (metric tons) used to produce 

adipic acid.

Annual percent nitrous oxide (N2O) emission 

reduction for all production units combined.

G Ammonia 

Production

Annual ammonia production (metric tons, sum of all 

process units reported within subpart G).

Annual methanol production (metric tons) for each 

process unit.

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) for each 

process unit.

Q Iron and Steel 

Production

If you use the carbon mass balance method in 40 

CFR §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, calculated 

as specified in Equation Q-9 in the final rule 

amendments. Do not include fuel used in a 

stationary combustion unit where emissions are 

reported under subpart C.

If you use the carbon mass balance method in 40 

CFR §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 subpart Q, calculated as specified 

in Equation Q-10 of subpart Q being finalized in 

today’s action.

If you use the carbon mass balance method in 40 

CFR 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 subpart Q, calculated 

as specified in Equation Q-11 of subpart Q being 

finalized in today’s action.

If you use the carbon mass balance method in 40 

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

weighted average carbon content of all gaseous, 

liquid, and solid fuels (combined) included in 

Equation Q-9 of subpart Q being finalized in 

today’s action, calculated as specified in 

Equation Q-12 of subpart Q being finalized in 

today’s action.
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Subpart Subpart Name New Data Element Description

If you use the carbon mass balance method in 40 

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

weighted average carbon content of all non-fuel 

inputs to all furnaces (combined) included in 

Equation Q-10 of subpart Q being finalized in 

today’s action, calculated as specified in 

Equation Q-13 of subpart Q being finalized in 

today’s action.

If you use the carbon mass balance method in 40 

CFR 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 Equation Q-11 of subpart Q 

being finalized in today’s action, calculated as 

specified in Equation Q-14 of subpart Q being 

finalized in today’s action.

S Lime 

Manufacturing

Annual quantity (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 CEMS method to calculate GHG 

emissions: Name and annual quantity (in metric 

tons) of each product. If using the mass balance 

method to calculate GHG emissions: Name and annual 

quantity (in metric tons) of each product used in 

Equations X-1, X-2, and X-3 of subpart X.

If using the CEMS method to calculate GHG 

emissions: Name and annual quantity (in metric 

tons) of each carbon-containing feedstock. If 

using the mass balance method to calculate GHG 

emissions: Name and annual quantity (in metric 

tons) of each carbon-containing feedstock used in 

Equations X-1, X-2, and X-3 of subpart X.

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: Percentage of annual 

heat input, individually for each fossil fuel 

type.

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), the EPA is changing the current recordkeeping and 

reporting methods used by respondents. These revisions do not 

result in a change in the data elements entered by respondents 

into the EPA’s e-GGRT system, but rather in the way that the 

data are received and used by the e-GGRT system. Refer to 
19

section 4(b)(ii) for a discussion of changes in this required 

activity. Refer to section 5(b) for more information about the 

EPA’s e-GGRT system. The current requirement to maintain records 

of these data elements in any format selected by reporters will

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 will be extended from 

three to five years. Refer to section 3(e) for the 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 

will result in additional burden are also specified in Table 1 

of Attachment 1.

Reporting New Data Elements. For each of the 21 new data 

elements required to be reported, respondents will 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 Verification Tool. During their first 

session using the inputs verification tool, respondents will

need to spend time becoming familiar with how the tool operates 

within e-GGRT. The new requirement to use the inputs 

verification tool does not result in any change in the 

respondent activity of entering these data into e-GGRT. 

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

required under the rule. However, “inputs to equations” data 

elements are entered into a new inputs verification tool within 

e-GGRT and are not reported to the EPA. Refer to section 5(b) 

for further discussion about the tool. The table below specifies 
20

the number of “inputs to equations” data elements per subpart 

that respondents 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

Not to be Reported, 

But Instead to be 

Entered into the 

Inputs Verification 

Tool

C General Stationary Fuel 

Combustion— Stationary 

fuel combustion sources

(e.g., individual units, 

aggregations of units, 

common pipes, or common 

stacks) excluding those 

that contain at least one 

combustion unit connected 

to a fuel-fired electric 

generator owned or 

operated by an entity 

that is subject to 

regulation of customer 

billing rates by the 

public utility commission 

(PUC) (excluding 

generators connected to 

combustion units subject 

to 40 CFR part 98, 

subpart D) and that are 

located at a facility for 

which the sum of the 

nameplate capacities for 

all electric generators 

specified in paragraph 

(f)(1) of this section is 

greater than or equal to 

1 megawatt electric 

output1

262 26

E Adipic Acid Production 21 11

F Aluminum Production 29 29

G Ammonia Manufacturing 8 8

H Cement Production 16 14

K Ferroalloy Production 13 13

N Glass Production 3 3

O HCFC-22 Production and 

HFC-23 Destruction 15 12

P Hydrogen Production 7 7

Q Iron and Steel 86 85
21

Subpart Source Category

Number of “Inputs to Equations” 

Data Elements

Currently 

Required to be 

Reported

Not to be Reported, 

But Instead to be 

Entered into the 

Inputs Verification 

Tool

Production

R Lead Production 10 10

S Lime Manufacturing (nonCEMS) 9 9

U Miscellaneous Uses of 

Carbonate 6 6

V Nitric Acid Production 21 21

X Petrochemical Production 19 19

Y Petroleum Refineries 75 70

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 

4

3

1 These subpart C sources may elect to report inputs to emission equations 

rather than use IVT. Additionally, the reporting requirements are not amended 

for stationary fuel combustion sources that contain at least one combustion 

unit connected to a fuel-fired electric generator owned or operated by an

entity that is subject to regulation of customer billing rates by the PUC 

(excluding generators connected to combustion units subject to 40 CFR part 

98, subpart D) and that are located at a facility for which the sum of the 

nameplate capacities for all electric generators specified in paragraph 

(f)(1) of this section is greater than or equal to 1 megawatt electric 

output.

2 Includes one deferred input to an emission equations, 40 CFR 98.3(d)(3)(v), 

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

reporters under 40 CFR part 98, subpart C.

Recordkeeping for “Inputs to Equations” Data Elements

Entered into the Inputs Verification Tool. Respondents will 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 download this 
22

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 does 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 9 subparts was estimated. 

5(b) Collection Methodology and Management

To collect data currently reported under the GHGRP, the EPA 

previously established a central repository of inventory data 

for all respondents, e-GGRT. Respondents report data 

electronically, and the EPA stores the data in the database. The 

e-GGRT 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 revisions to Part 98, 

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

the new data elements via e-GGRT. Additionally, for verification 

purposes, they enter their “inputs to equations” data elements 
23

into a new inputs verification tool embedded within e-GGRT, 

without reporting these data.

The inputs verification tool is deployed within e-GGRT and 

is integrated without interrupting the current electronic 

reporting process. Reporters enter “inputs to equations” data 

elements (that EPA is removing from the reporting requirements)

into the inputs verification tool along with the data required 

to be reported in the annual report. The tool uses 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 

does not retain the entered “inputs to equations” data elements

for which the EPA is removing the reporting requirement. 

Accordingly, the EPA does not have access to these “inputs to 

equations” data elements. Instead, the EPA will rely on the 

verification summary, which will become accessible to the EPA 

when annual reports are submitted, as a first step for 

conducting verification once the annual report is submitted.

The new inputs verification tool within e-GGRT follows 

Agency standards for design, security, data element and 

reporting format conformance, and accessibility. The EPA 

designed the system in an attempt to minimize respondents’ 

burden by embedding the new inputs verification tool within eGGRT. 

5(c) Small Entity Flexibility

This information collection will not have a significant 

economic impact on a substantial number of small entities.

Nonetheless, the EPA has tried to reduce the impact of this 

information collection on small entities. The EPA supports a 
24

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

questions on the provisions in this rulemaking.

5(d) Collection Schedule

All data elements under this information collection will be 

entered into the inputs verification tool or 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 the 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. 

The burden statement for this information collection is in 

section 6(g). 

6(a) Estimating Respondent Burden

The EPA estimates the labor hours for the first-year 

activity of training to use the inputs verification tool to be 

1.2 hour per applicable respondent. The EPA estimates the labor 

hours for the annual activity of reporting of new data elements 

to average 1.3 hour per applicable respondent. Tables 1 through 

3 in Attachment 1 present an itemized breakdown of the reporting 
25

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 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, 

the 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, the EPA estimates the cost per applicable 

respondent to be $67. For the annual activity of reporting the 

new data elements, the EPA estimates the average annual cost per 

applicable respondent to be $93. The EPA estimates that the 

annual average cost to all respondents to be $182,592 for 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 rule, the 

incremental burden to the EPA is associated with the additional 

 

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).
26

time to review the new data elements that will be reported (see 

section 4(b)(i)). 

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

be reported for multiple subparts and a reduction in the EPA 

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

the burden estimate because the verification summaries will 

still allow the 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 $10,700.

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.

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

Costs

The EPA estimates that 5,795 respondents will complete the 

one-time 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 6,664 hours and 

$383,145. The EPA estimates that 592 respondents per year will 

complete the annual activity of reporting the new data elements,
27

and that the burden and costs for such respondents over the 

three years covered by this information collection are 2,864

hours and $164,630. Based on these estimates, the total burden 

and costs for all respondents over the three years covered by 

this information collection is 9,528 hours and $547,775.

6(e) Bottom Line Burden Hours and Costs

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

collection, reporting, and recordkeeping activities is presented 

in Attachment 1. The EPA estimates the average annual respondent 

burden and cost over the three years of this information 

collection to be 2,221 labor hours at a cost of $182,592 per 

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

verification tool and 955 labor hours at a cost of $54,877 per 

year for the annual activity of reporting the new data elements. 

Based on these estimates, the average annual respondent burden 

and cost over the three years of this information collection is

3,176 labor hours at a cost of $182,592 per year.

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

and costs are presented in Attachment 2. The average annual 

Agency burden and cost over the three years of this information 

collection is 240 labor hours at a cost of $10,700.

6(f) Reasons for Change in Burden

The overall reporting for Part 98 will increase slightly

due to these revisions to Part 98. Refer to section 4 for a 

summary of the new data elements and respondent activities that 

will increase the respondent burden. The EPA estimates the 

increase in burden for all respondents to be 9,528 hours over 

the first three years of this information collection request, 

consisting of 6,664 hours for the first-year activity of 

learning new procedures for the verification tool and 2,864
28

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.

The overall burden of the final action is reduced from the 

burden estimated for proposal by 1,248 hours. The change is due 

to: (1) using the most current number of reporters for each 

subpart for the burden estimate (from 2012), which is a slightly 

larger number than in 2011, and increases the hours by 68, and 

(2) decreasing costs from reporting new data elements due to 

reducing the number of data elements to be reported from 26 to 

21, which reduces hours by 1,326 hours. 

6(g) Burden Statement

Attachment 1 presents the average annual respondent burden 

for each sector and activity. For the 5,795 respondents subject 

to the 23 subparts required to report “inputs to emission 

equations” data elements, the 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 2,221 

hours, or 0.4 hours per respondent. The EPA also determined 

there is no burden due to delaying reporting of six subpart W 

data elements related to specific types of exploratory wells for 

two years.

For the 592 respondents subject to subparts E, G, H, P, Q, 

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

reporting new data elements to average 1.3 hour per respondent

per year. This estimate includes the time to gather available 

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

into e-GGRT. For all such respondents, the average annual 
29

respondent burden over the 3-year collection of information 

period is estimated to be 955 hours. 

For all respondents, the average annual respondent burden 

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

be 3,176 hours. The average annual burden to the EPA for this 

period is estimated to be 240 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 the 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, the 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 

Constitution Avenue, NW, Washington, D.C. The EPA Docket Center 
30

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.