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MEMORANDUM 

DATE: May 30, 2014 

TO: Docket # EPA-HQ-OAR-2014-0410

FROM: Jessica Gordon, Lisa Grogan-McCulloch, US EPA/Climate Change Division

SUBJECT: Publication of Certain Aggregated Greenhouse Gas Data

Background 

On October 30, 2009, the EPA published the Greenhouse Gas (GHG) Reporting Rule, 40 CFR Part 98, requiring annual 

reporting of GHG data from a broad range of industry sectors. Under the Greenhouse Gas Reporting Rule and its 

subsequent amendments (hereinafter referred to as ‘‘Part 98’’), the EPA requires annual reporting of data from certain 

facilities and suppliers. Through a series of rulemaking actions, the EPA determined which categories of data elements 

qualify for protection as confidential business information (CBI) under EPA’s regulations at 40 CFR Part 2, subpart B.

Many data elements determined to be CBI at the facility or supplier level may be published as aggregated values at the 

subpart level (e.g., industry total or weighted average) or corporate-level (for subparts OO, PP, and QQ) if the 

aggregation shields the underlying facility or supplier-level CBI. In the Federal Register notice, Greenhouse Gas Reporting 

Rule: Publication of Aggregated Greenhouse Gas Data, Docket ID EPA-HQ-OAR-2014-0410, the EPA outlined criteria for 

determining whether aggregated CBI data may be published without risk of disclosing the underlying CBI data. These 

criteria are summarized below.

Criteria for Aggregating Data at the National or Regional Level

1a. The data used to calculate the aggregated value must be reported by at least three separate facilities or 

suppliers that have no common ownership or operator;

2a. No single owner or operator can contribute more than x percent to a particular aggregated value. (The EPA will 

not disclose the value of x);

3a. No two owners or operators can contribute more than y percent of a particular aggregated value. (The EPA will 

not disclose the value of y); and

4a. No underlying facility or supplier-level CBI can be back-calculated or otherwise determined using the aggregated 

value in combination with other publicly available data, including any facility-, supplier-, regional-, or nationallevel data published by the GHGRP or any other data likely to be available to owners or operators.

Criteria for Corporate-Level Supplier Data in Subparts OO, PP, and QQ

1b. The aggregated value includes information from two or more products supplied by the reporter;

2b. No single product can contribute more than z percent of the corporate-level total to a particular aggregated 

value. (The EPA will not disclose the value of z);

3b. Publication of the data does not allow for values (from another owner) that do not themselves meet criteria 1b 

and 2b to be back-calculated from national- or regional-level data aggregations; and
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4b. If a company only reports data on a single product type, the products within that product type contain different 

GHGs, different amounts of that GHG per product, or both.

As we explained in the Federal Register notice, the EPA will publish only aggregated values that meet all of the final 

criteria in the appropriate set (national/regional aggregation or corporate-level aggregation) that the EPA adopts after 

considering comment on the Federal Register notice. We intend to hold confidential the values of x and y in criteria 2a 

and 3a and the value of z in criterion 2b to provide additional protection of the facility and supplier-level data. 

Table 1 of this memorandum contains a list of data elements that the EPA is presently considering for aggregation. This 

table presents the subpart of the data to be evaluated for aggregation; the data element description; whether this 

applies to Continuous Emissions Monitoring Systems (CEMS), non-CEMS facilities, or the combination of the two (“CEMS 

& non-CEMS”); the rule citation; and the aggregation level (e.g., national, state).

The EPA will consider comments on the Federal Register notice and develop the final criteria for publication. The EPA 

will then evaluate certain Reporting Year 2013 data, particularly the data elements listed in Table 1, against the final 

criteria. For aggregated values that meet all of the applicable final criteria for publication, the EPA will then individually 

notify each affected reporter (in writing and in a manner providing confirmation of receipt, as specified under the EPA’s 

CBI regulations at 40 CFR 2.204(e)(1)) about which data elements the EPA intends to aggregate and the intended level of 

aggregation. The EPA will then give the reporter at least ten days to file for judicial review, as required under 40 CFR 

2.205(f)(2), before publicly releasing any aggregated values.

For aggregated values to be published in any future year, the final criteria must be met for the relevant data element(s) 

for that particular year. As long as the aggregation criteria remain consistent, the EPA does not anticipate publishing

additional Federal Register notices, but will continue to provide written notice to individual reporters in advance of 

publishing aggregated values, as described above.

Please see the Federal Register notice for a discussion of the comments we request on the data elements and 

aggregation levels in this table and for instructions on how to comment.

Table 1. List of Data Aggregations that the EPA May Evaluate Against the Final Aggregation Criteria.

Subpart Subpart 

Description

Data Element Description CEMS/Non-CEMS Rule Citation Aggregation Level 

AA Pulp & Paper 

Manufacturing

Unbleached virgin chemical pulp 

production

N/A 98.276(k) National (Total)

Total annual steam purchases N/A 98.276(j) National (Total)

CC Soda Ash 

Manufacturing

Soda ash production CEMS & non-CEMS 98.296(a)(2), 

98.296(b)(3)

National (Total)

EE Titanium Dioxide 

Production

Titanium dioxide annual production CEMS & non-CEMS 98.316(a)(3), 

98.316(b)(4)

National (Total)

Annual Production of Carbon 

Containing Waste 

CEMS & non-CEMS 98.316(a)(5), 

98.316(b)(7)

National (Total)

Average Carbon Content of Carbon 

Containing Waste

non-CEMs only 98.316(b)(11) National (Weighted 

average)

Annual Consumption of calcined 

petroleum coke 

CEMS & non-CEMS 98.316(a)(2), 

98.316(b)(3)

National (Total)
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Subpart Subpart 

Description

Data Element Description CEMS/Non-CEMS Rule Citation Aggregation Level 

Sampling analysis results of carbon 

content of petroleum coke

non-CEMs only 98.316(b)(13) National (Weighted 

average)

G Ammonia 

Manufacturing

Annual Urea Production non-CEMs only 98.76(b)(12) National (Total)

GG Zinc Production Annual production quantity for each 

zinc product 

CEMS & non-CEMS 98.336(a)(2), 

98.336(b)(3)

National (Total)

H Cement 

Production

Annual Cement Production CEMS & non-CEMS 98.86(a)(2), 

98.86(b)(3)

National (Total)

Clinker production CEMS & non-CEMS 98.86(a)(1), 

98.86(b)(2)

National (Total)

I Electronics 

Manufacturing

Annual production in terms of 

substrate surface area (e.g., silicon, 

PV-cell, glass)

N/A 98.96 (e) National for each 

subsector 

(semiconductor, 

LCD, PV, etc.)

(Total). For 

semiconductors, 

also by wafer size, 

by device type (e.g., 

memory vs. logic, as 

indicated by the 

World Fab 

Forecast), by fab 

level of abatement

(e.g. percentage 

groupings such as 

0-50%, 50-75%, 75-

90%, 90-100%), by 

Si vs. other 

substrates (as 

indicated by the 

World Fab Forecast)

(Total).

Annual manufacturing capacity of 

each fab at the facility used to 

determine the annual manufacturing 

capacity of the facility in Equation I-5 

of subpart I

N/A 98.96 (a) National for each 

subsector 

(semiconductor, 

LCD, PV, etc.) 

(Total). For 

semiconductors, 

also by wafer size, 

by device type (e.g., 

memory vs. logic, as 

indicated by the 

World Fab 

Forecast), by fab 

level of abatement

(e.g. percentage 

groupings such as 

0-50%, 50-75%, 75-

90%, 90-100%), by 

Si vs. other 

substrates (as 

indicated by the 

World Fab Forecast)

(Total).
4

Subpart Subpart 

Description

Data Element Description CEMS/Non-CEMS Rule Citation Aggregation Level 

K Ferroalloy 

Production

Annual facility ferroalloy product 

production capacity

CEMS & non-CEMS 98.116(a) National (Total)

MM Suppliers of 

Petroleum 

Products

Quantity of each Product in Table 

MM-1 entering refineries

N/A 98.396(a)(2) National and by 

PADD (Total)

Quantity of each Product in Table 

MM-1 exiting refineries

N/A 98.396(a)(6) National and by 

PADD (Total)

Quantity of each biomass product in 

Table MM-2 entering refineries to be 

co-processed with petroleum 

feedstocks

N/A 98.396(a)(14) National and by 

PADD (Total)

For each product in Table MM-1, CO2 

associated with that product exiting 

refineries MINUS Total CO2 

associated with that product entering 

refineries

N/A 98.396(a)(16), 

98.396(a)(17), 

98.396(19)

National and by 

PADD (Total)

For each product in Table MM-2, CO2 

associated with each biomass based 

feedstock entering refineries for coprocessing with petroleum feedstocks

N/A 98.396(a)(18) National and by 

PADD (Total)

Volume of crude oil received at 

refineries

N/A 98.396(a)(20) National and by 

PADD (Total)

Volume of bulk NGLs received for 

processing at refineries

N/A 98.396(a)(21) National and by 

PADD (Total)

Volume of crude injected into crude 

supplies/reservoirs by refineries

N/A 98.396(a)(22) National and by 

PADD (Total)

Volume of each product listed in 

Table MM-1 imported

N/A 98.396(b)(2) National (Total)

CO2 associated with each product in 

table MM-1 that is imported

N/A 98.396(b)(7) National (Total)

Volume of each product listed in 

Table MM-1 exported

N/A 98.396(c)(2) National (Total)

CO2 associated with each product in 

table MM-1 that is exported

N/A 98.396(c)(8) National (Total)

N Glass Production Glass Production CEMS & non-CEMS 98.146(a)(2), 

98.146(b)(3)

National (Total)

Annual Quantity of carbonate basedraw material charged to glass melting 

furnaces 

CEMS only 98.146(a)(1) National (Total and 

by carbonate raw 

material)

Annual Quantity of carbonate basedraw material charged to all glass 

furnaces combined

non-CEMS only 98.146(b)(2) National (Total and 

by carbonate raw 

material)

Decimal fraction of calcination

achieved for each carbonate-based 

raw material, if a value other than 1.0 

is used to calculate process mass 

emissions of CO2

98.146(b)(6) National (Average, 

by carbonate type)
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Subpart Subpart 

Description

Data Element Description CEMS/Non-CEMS Rule Citation Aggregation Level 

Mass fraction of each sample 

analyzed for all tests used to verify 

the carbonate-based mineral mass 

fraction charged to a furnace 

non-CEMS only 98.146(b)(5)(iii) National (Average, 

by carbonate type)

NNFRACSupplier of 

Natural Gas & 

Natural Gas 

Liquids

National CO2 value associated with 

NGL Supply (across all 5 NGLs)

N/A 98.406(a)(6) National (Total)

National CO2 value associated with 

each of the 5 NGLs (ethane, propane, 

butane, isobutane, pentanes plus) 

supplied minus the amount received

N/A 98.406(a)(7) National (Total)

National quantity of each of the 5 

NGLs supplied

N/A 98.406(a)(1) National (Total)

National quantity of each of the 5 

NGLs received for processing

N/A 98.406(a)(2) National (Total)

Volume of natural gas received for 

processing

N/A 98.406(a)(3) National (Total)

Volume of bulk NGLs received for 

processing

N/A 98.406(a)(4)(i) National (Total)

Volume of propane odorized and 

delivered to others

N/A 98.406(a)(5) National (Total)

Quantity of bulk NGLs supplied N/A 98.406(a)(1) National (Total)

NN-LDC Supplier of 

Natural Gas & 

Natural Gas 

Liquids

Volume of natural gas received at city 

gate stations

N/A 98.406(b)(1) National (Total)

Volume of vaporized LNG withdrawn 

from storage

N/A 98.406(b)(3) National (Total)

Volume of natural gas received from 

local production

N/A 98.406(b)(5) National (Total)

Volume of natural gas delivered to 

customer meters receiving above 

460,000 Mscf per year

N/A 98.406(b)(7) National (Total)

OO Suppliers of 

Industrial GHGs

Aggregated net CO2e supply to U.S. 

(production + imports - exports -

transformation - destruction) of all 

gases

N/A 98.416(a)(1)-

(13)

National and 

corporate level 

(Total)

Aggregated net supply to U.S. of a 

single gas

N/A 98.416(a)(1)-

(13)

National (Total). 

Gases may be 

aggregated 

together if one or 

more gas fails to 

meet publication 

criteria.

Aggregated components of supply to 

U.S. (aggregated production, 

aggregated imports, aggregated 

exports, aggregated transformation, 

aggregated destruction) of all gases.

Provided in tCO2e and/or tons 

chemical

N/A 98.416(a)(1)-

(13)

National and 

corporate level 

(Total)
6

Subpart Subpart 

Description

Data Element Description CEMS/Non-CEMS Rule Citation Aggregation Level 

Aggregated net supply by gas group 

(e.g., fully fluorinated GHGs (including 

saturated PFCs, SF6, and NF3 as well 

as other fully fluorinated, very longlived compounds such as PFPMIE); 

saturated HFCs (may divide these into

more than one group based on 

lifetime); saturated HFEs (may divide 

these into more than one group 

based on lifetime or application); 

unsaturated PFCs; unsaturated HFCs;

unsaturated HFEs; and other very 

short-lived compounds)

N/A 98.416(a)(1)-

(13)

National and 

corporate level 

(Total). Gas groups 

may be aggregated

together if one or 

more groups fails to 

meet publication 

criteria.

P Hydrogen 

Production

Hydrogen Production CEMS & non-CEMS 98.166(a)(2), 

98.166(b)(3)

National (Total)

Ammonia Production CEMS & non-CEMS 98.166(a)(3), 

98.166(b)(4)

National (Total)

PP Suppliers of CO2 CO2 Supplied by CO2 Capture 

Facilities

N/A 98.426(c) National and by 

State (Total)

CO2 Imported N/A 98.426(a)(1), 

98.426(b)(1), 

98.426(d)

National (Total)

CO2 transferred to the following 

applications: food and beverage, 

municipal water/wastewater, metal 

fabrication, plant growth, fumigants, 

pulp and paper mills, cleaning and 

solvent use, fire fighting, storage of 

explosives, enhanced oil and natural 

gas recovery, long-term storage, 

research and development, other 

uses

N/A 98.426(f) National, by State, 

and by natural 

dome (Total)

CO2 Exported N/A 98.426(a)(1),

98.426(b)(1),

98.426(d)

National (Total)

QQ Imports and 

Exports of 

equipment precharges with FGHGs or 

containing FGHGs in closedcell foams

Aggregate net CO2e supply to U.S. 

(imports - exports)

N/A 98.436(a)(1), 

98.436(a)(6)(i), 

98.436(b)(1), 

98.436(b)(6)(i)

National and 

corporate level 

(Total)

Aggregate net CO2e supply to U.S. in 

equipment

N/A 98.436(a)(1) National and 

corporate level 

(Total)

Aggregate net CO2e supply to U.S. in 

foam

N/A 98.436(a)(1) National and 

corporate level 

(Total)

Aggregate net CO2e supply by gas 

subgroups (e.g., fully fluorinated 

GHGs (including saturated PFCs, SF6, 

and NF3 as well as other fully 

fluorinated, very long-lived 

compounds such as PFPMIE); 

saturated HFCs (may divide these into 

more than one group based on 

lifetime or application); saturated 

N/A 98.436(a)(2)-(4) National and 

corporate level 

(Total)
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Subpart Subpart 

Description

Data Element Description CEMS/Non-CEMS Rule Citation Aggregation Level 

HFEs (may divide these into more 

than one group based on lifetime or 

application); unsaturated PFCs; 

unsaturated HFCs; unsaturated HFEs;

and other very short-lived 

compounds)

Aggregate net CO2e supply by

individual gases

N/A 98.436(a)(2)-(4) National and 

corporate level 

(Total)

Aggregate net CO2e supply by

individual equipment types

N/A 98.436(a)(2) National and 

corporate level 

(Total)

Aggregated net number of units 

supplied of individual equipment 

types

N/A 98.436(a)(2) National (Total)

Aggregate net CO2e supply by

individual gas(es) and type(s) of 

equipment

N/A 98.436(a)(2) National and 

corporate level 

(Total)

R Lead Production Total Lead Production CEMS & non-CEMS 98.186(a)(3), 

98.186(b)(4)

National (Total)

S Lime 

Manufacturing

Lime product sold CEMS only 98.196(a)(6) National (Total)

Lime product not sold CEMS only 98.196(a)(8) National (Total)

Annual amount of CO2 captured for 

use in the on-site process 

non-CEMs only 98.196(b)(17)(i) National (Total)

T Magnesium 

Production

Magnesium produced or processed N/A 98.206(c) National and by 

industry segment 

(re-melt, die 

casting, smelting, 

refining) (Total)

UU Injection of CO2 Mass of CO2 received for injection N/A 98.476(a)(1), 

98.476(b)(4), 

98.476(c) 

National, by State, 

by AAPG Province 

(Total)

V Nitric Acid 

Production

Nitric Acid Production N/A 98.226(e) National (Total)

Type of Nitric Acid Process N/A 98.226 (k) National (Totals, 

production share by 

type)

X Petrochemical 

Production

Acrylonitrile produced CEMS & non-CEMS 98.246(a)(5), 

98.246(b)(8)

National (Total)

Carbon black produced CEMS & non-CEMS 98.246(a)(5), 

98.246(b)(8)

National (Total)

Ethylene produced CEMS & non-CEMS, 

including optional 

combustion 

methodology from 

98.243(d)

98.246(a)(5), 

98.246(b)(8), 

98.246(c)(5)

National (Total)

Ethylene dichloride produced CEMS & non-CEMS 98.246(a)(5), 

98.246(b)(8)

National (Total)

Ethylene oxide produced CEMS & non-CEMS 98.246(a)(5), 

98.246(b)(8)

National (Total)
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Subpart Subpart 

Description

Data Element Description CEMS/Non-CEMS Rule Citation Aggregation Level 

Y Petroleum 

Refineries

Coke burn-off quantity per cycle or 

measurement period for catalytic 

cracking units, traditional fluid coking 

units and catalytic reforming units

N/A 98.256(f)(13) National (Total)

Z Phosphoric Acid 

Production

Phosphoric Acid Production N/A 98.266(a) National (Total)

Phosphoric Acid Production by origin 

of phosphate rock

N/A 98.266(a) National (Total)

Phosphoric Acid production capacity N/A 98.266(b) National (Total)

Annual arithmetic average percent 

inorganic carbon or carbon dioxide in 

phosphate rock

N/A 98.266(c) National (Average)

Annual phosphate rock consumption 

from monthly measurement records 

by origin

N/A 98.266(d) National (Total)