C E F G H K N O P Q R S U V X Y Z AA BBCCEEGGTT 1. REPORTING REQUIREMENTS a. Initial Training with Inputs Verification Tool (a) i. Number of Respondents Per Year (b) 5795 (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) 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) b. Annual Reporting of New Data Elements (e) i. Number of Respondents per Year (b) 592 0 3 0 22 82 0 0 0 74 126 0 75 0 35 64 0 0 111 0 0 0 0 0 iii. Number of New Data Elements (f) 21 0 2 0 2 3 0 0 0 2 6 0 1 0 1 2 0 0 2 0 0 0 0 0 iii. Number of Occurrences Per Respondent Per Year (d) 1 0 1 0 1 1 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 1 3 0 0.5 0 0.5 1 0 0 1 0 0 0 0 0 2. SUBTOTAL COST AND HOURS FOR BURDEN ITEM GROUPS a. Respondent Hours i. Technical 5,795 (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) 580 (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) 290 (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 6,664 (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) $342,600 (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) $18,167 (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) $22,377 (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 $383,145 (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 830 0 3 0 22 123 0 0 0 74 378 0 38 0 18 64 0 0 111 0 0 0 0 0 ii. Clerical (h) 83 0 0 0 2 12 0 0 0 7 38 0 4 0 2 6 0 0 11 0 0 0 0 0 iiii. Managerial (h) 42 0 0 0 1 6 0 0 0 4 19 0 2 0 1 3 0 0 6 0 0 0 0 0 iv. Total 955 0 3 0 25 141 0 0 0 85 435 0 43 0 20 74 0 0 128 0 0 0 0 0 b. Respondent Costs i. Technical (i) $49,070 $0 $177 $0 $1,301 $7,272 $0 $0 $0$4,375$22,347$0$2,217$0$1,035$3,784 $0 $0 $6,562 $0$0$0$0 $0 ii. Clerical (i) $2,602 $0 $9 $0 $69 $386 $0 $0 $0 $232 $1,185 $0 $118 $0 $55 $201 $0 $0 $348 $0$0$0$0 $0 iiii. Managerial (i) $3,205 $0 $12 $0 $85 $475 $0 $0 $0 $286 $1,460 $0 $145 $0 $68 $247 $0 $0 $429 $0$0$0$0 $0 iv. Total $54,877 0 198 0 1,455 8,132 0 0 0 4,893 24,992 0 2,479 0 1,157 4,231 0 0 7,339 0 0 0 0 0 3. TOTAL COST AND HOURS FOR ALL BURDEN ITEMS ANNUAL LABOR HOURS: Technical 6,625 Clerical 663 Managerial 331 Total Hours 7,619
ANNUAL COST: Technical $391,670 Clerical $20,769 Managerial $25,582 Total Cost $438,022
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 N O P Q R S U V X Y Z AA BBCCEEGGTT 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) 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) 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) b. Annual Reporting of New Data Elements (e) i. Number of Respondents per Year (b) 592 0 3 0 22 82 0 0 0 74 126 0 75 0 35 64 0 0 111 0 0 0 0 0 iii. Number of New Data Elements (f) 21 0 2 0 2 3 0 0 0 2 6 0 1 0 1 2 0 0 2 0 0 0 0 0 iii. Number of Occurrences Per Respondent Per Year (d) 1 0 1 0 1 1 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 1 3 0 0.5 0 0.5 1 0 0 1 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) 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) 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) 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) 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) 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) 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) 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) a. Respondent Hours i. Technical 830 0 3 0 22 123 0 0 0 74 378 0 38 0 18 64 0 0 111 0 0 0 0 0 ii. Clerical (h) 83 0 0 0 2 12 0 0 0 7 38 0 4 0 2 6 0 0 11 0 0 0 0 0 iiii. Managerial (h) 42 0 0 0 1 6 0 0 0 4 19 0 2 0 1 3 0 0 6 0 0 0 0 0 iv. Total 955 0 3 0 25 141 0 0 0 85 435 0 43 0 20 74 0 0 128 0 0 0 0 0 b. Respondent Costs i. Technical (i) $49,070 $0 $177 $0 $1,301 $7,272$0$0$0$4,375 $22,347$0$2,217$0$1,035$3,784 $0 $0 $6,562 $0$0$0$0$0 ii. Clerical (i) $2,602 $0 $9 $0 $69 $386 $0$0$0 $232 $1,185 $0 $118 $0 $55 $201 $0 $0 $348 $0$0$0$0$0 iiii. Managerial (i) $3,205 $0 $12 $0 $85 $475 $0$0$0 $286 $1,460 $0 $145 $0 $68 $247 $0 $0 $429 $0$0$0$0$0 iv. Total $54,877 0 198 0 1,455 8,132 0 0 0 4,893 24,992 0 2,479 0 1,157 4,231 0 0 7,339 0 0 0 0 0 3. TOTAL COST AND HOURS FOR ALL BURDEN ITEMS ANNUAL LABOR HOURS: Technical 830 Clerical 83 Managerial 42 Total Hours 955
ANNUAL COST: Technical $49,070 Clerical $2,602 Managerial $3,205 Total Cost $54,877
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 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) 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) 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) b. Annual Reporting of New Data Elements (e) i. Number of Respondents per Year (b) 592 0 3 0 22 82 0 0 0 74 126 0 75 0 35 64 0 0 111 0 0 0 0 0 iii. Number of New Data Elements (f) 21 0 2 0 2 3 0 0 0 2 6 0 1 0 1 2 0 0 2 0 0 0 0 0 iii. Number of Occurrences Per Respondent Per Year (d) 1 0 1 0 1 1 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 1 3 0 0.5 0 0.5 1 0 0 1 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) 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) 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) 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) 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) 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) 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) 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) a. Respondent Hours i. Technical 830 0 3 0 22 123 0 0 0 74 378 0 38 0 18 64 0 0 111 0 0 0 0 0 ii. Clerical (h) 83 0 0 0 2 12 0 0 0 7 38 0 4 0 2 6 0 0 11 0 0 0 0 0 iiii. Managerial (h) 42 0 0 0 1 6 0 0 0 4 19 0 2 0 1 3 0 0 6 0 0 0 0 0 iv. Total 955 0 3 0 25 141 0 0 0 85 435 0 43 0 20 74 0 0 128 0 0 0 0 0 b. Respondent Costs i. Technical (i) $49,070 $0 $177 $0 $1,301$7,272 $0 $0 $0 $4,375 $22,347 $0 $2,217 $0 $1,035$3,784 $0 $0 $6,562 $0 $0 $0 $0 $0 ii. Clerical (i) $2,602 $0 $9 $0 $69 $386 $0 $0 $0 $232 $1,185 $0 $118 $0 $55 $201 $0 $0 $348 $0 $0 $0 $0 $0 iiii. Managerial (i) $3,205 $0 $12 $0 $85 $475 $0 $0 $0 $286 $1,460 $0 $145 $0 $68 $247 $0 $0 $429 $0 $0 $0 $0 $0 iv. Total $54,877 0 198 0 1,455 8,132 0 0 0 4,893 24,992 0 2,479 0 1,157 4,231 0 0 7,339 0 0 0 0 0 3. TOTAL COST AND HOURS FOR ALL BURDEN ITEMS ANNUAL LABOR HOURS: Technical 830 Clerical 83 Managerial 42 Total Hours 955
ANNUAL COST: Technical $49,070 Clerical $2,602 Managerial $3,205 Total Cost $54,877
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 6387 7,619 $438,022 $0 $438,022 2 592 955 $54,877 $0 $54,877 3 592 955 $54,877 $0 $54,877 Total 7,571 9,528 $547,775 $0 $547,775 Average 2,524 3,176 $182,592 $0 $182,592 

## 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(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 1660 0.1 166 8 17 $8,603 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 286 14 29 $14,821

FOOTNOTES
aNumber of occurences is the number of states where affected sources will exist and each EPA Region (50 states + 10 EPA regions = 60 respondents). bNumber 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 1660 0.1 166 8 17 $8,603 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 166 8 17 $8,603

FOOTNOTES
aNumber of occurences is the number of states where affected sources will exist and each EPA Region (50 states + 10 EPA regions = 60 respondents). bNumber 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 1660 0.1 166 8 17 $8,603 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 166 8 17 $8,603

FOOTNOTES
aNumber of occurences is the number of states where affected sources will exist and each EPA Region (50 states + 10 EPA regions = 60 respondents). bNumber 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 1 286 14 29 329 $14,821 $0 $14,821 2 166 8 17 191 $8,603 $0 $8,603 3 166 8 17 191 $8,603 $0 $8,603 Total 618 31 62 711 $32,026 $0 $32,026 Average 206 10 21 237 $10,675 $0 $10,675 

## 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