1

MEMORANDUM

TO: Jessica Gordon, Rachel Schmeltz, EPA

FROM: Donna Lazzari, Jason Renzaglia, Tracy Curtis, ERG

DATE: September 30, 2013

SUBJECT: Assessment of Emissions and Cost Impacts of Final 2013 Revisions to the 

Greenhouse Gas Reporting Rule and Confidentiality Determinations for New or 

Substantially Revised Data Elements 

EPA intends to update the Global Warming Potentials (GWPs) in Table A-1 of subpart A 

to match the GWPs published by the Intergovernmental Panel on Climate Change (IPCC) in the 

2007 Fourth Assessment Report. Additionally, EPA is finalizing technical corrections and other 

amendments to 30 subparts of the GHG reporting rule (40 CFR part 98).

This memorandum explains how reporters will be affected by changes to the GWPs in the 

GHG reporting rule and discusses the impacts of the technical corrections and other 

amendments. The memorandum is organized as follows:

Section 1.0: Background and Introduction for GWP Revisions

Section 2.0: Identification of Subparts Affected by the GWP Revisions in Subpart A

Section 3.0: Summary of Impacts and Small Entity Impacts - All Reporters

Section 4.0: Methodology for Estimating Impacts to Current Reporters

Section 5.0: Methodology for Estimating Impacts to New Reporters

Section 6.0: Impacts of Other Technical Corrections and Amendments

1.0 BACKGROUND AND INTRODUCTION FOR GWP REVISIONS

Facilities affected by the GHG reporting rule must report their GHG emissions to EPA

through the electronic Greenhouse Gas Reporting Tool (e-GGRT). In general, to calculate GHG 

emissions, reporters use the GWPs in Table A-1 to subpart A of the GHG reporting rule. EPA is 

finalizing updates to the GWPs in Table A-1 using the GWPs from the IPCC 2007 Fourth 

Assessment Report1.

 

1

IPCC, 2007. Climate Change 2007: Synthesis Report. Contribution of Working Groups I, II and III to the Fourth 

Assessment. Report of the Intergovernmental Panel on Climate Change [Core Writing Team, Pachauri, R.K and 

Reisinger, A. (eds.)]. IPCC, Geneva, Switzerland, 104 pp
2

This section explains how the changes to Table A-1 will affect reporters. Two kinds of 

reporters are described in this memorandum: 

 Current reporters are those reporters that are already subject to the GHG 

reporting rule and have already reported their emissions to e-GGRT for the year 

2010 and 2011 or for only the year 2011. Emissions data for these reporters is 

available through the EPA website.

 New reporters are those reporters that are not currently affected by the GHG 

reporting rule, but would become subject to the rule as a result of the changes to

Table A-1.

1.1 How GWPs Affect Emissions and Applicability to the GHG Reporting Rule

A change to the GWP for a GHG will change the calculated emissions or supply of that 

gas and might also change the number of facilities or suppliers that are subject to the GHG

reporting rule. The number of facilities or suppliers could change because for some subparts

applicability to the GHG reporting rule is based on the amount of GHG that is either consumed, 

generated, emitted, imported, or exported over a calendar year, expressed in carbon dioxide 

equivalents (CO2e). Carbon dioxide equivalent is a metric used to compare the emissions of 

various GHGs based on their GWP. Because different GHGs have different heat trapping 

capabilities and atmospheric lifetimes, they are not directly comparable without translating 

emissions into a common unit of measure. The GWP is a measure of the total energy that a gas 

absorbs over a particular period of time (usually 100 years) compared to carbon dioxide, which 

has a GWP of 1.0. The CO2e for a specific gas is derived by multiplying the mass of the gas by 

the associated GWP. For example, methane currently has a GWP of 21. A facility that emits 

1,000 tons of CO2 emits 1,000 tons per year of CO2e. A facility that emits 1,000 tons of methane 

emits 21,000 tons per year of CO2e.

Based on revised radiative forcing research, the IPCC in the 2007 Fourth Assessment 

Report updated the GWP values for the following compounds: methane, nitrous oxide, certain

hydrofluorocarbons, perfluorinated compounds, and fluorinated ethers, substances controlled by 

the Montreal protocol, and certain hydrocarbons and other compounds with direct warming 

effects. The revised GWP values by IPCC represent an increase in the GWP for methane (CH4), 

a slight decrease for nitrous oxide (N2O), an increase for 10 fluorinated gases, and a decrease for 

three fluorinated gases. The GWP for all other GHGs currently on Table A-1 are unchanged. The 

GHGs that are covered by the GHG reporting rule are carbon dioxide (CO2), CH4, N2O, sulfur 

hexafluoride (SF6), hydrofluorocarbons, perfluorocarbons, and other fluorinated GHGs (which 

include fluorinated ethers). The GHG reporting rule does not require reporting of emissions of 

the Montreal protocol substances or the hydrocarbons with direct effects (dimethylether, 

methylene chloride, and methyl chloride). Appendix A of this memorandum lists the compounds 

covered by the GHG reporting rule along with the original GWPs and the final GWP revisions. 
3

Currently, some source categories under 40 CFR part 98 provide calculation 

methodologies and reporting requirements for fluorinated greenhouse gases (F-GHGs) or

fluorinated heat transfer fluids (F-HTFs) for which GWPs were not available in the IPCC 

assessment reports or other scientific assessments at promulgation. The GWPs in Table A-1 of 

subpart A are primarily used for threshold calculations to determine rule applicability (40 CFR 

98.2(b)) and for reporting total GHG emissions or supply in CO2e for each facility or supplier 

(40 CFR 98.3(c)(4)). Those F-GHGs or F-HTFs whose GWPs are currently not listed in Table 

A-1 are not included in threshold calculations for applicability or in the CO2e totals reported by 

facilities and suppliers, but are instead reported in metric tons of substance emitted or supplied 

(40 CFR 98.3(c)(4)). 

Revisions to the GWPs affect the calculation of CO2e from facility emissions, and thus 

any increase in the GWPs in a threshold analysis could cause a given facility or supplier to 

exceed the emissions reporting threshold, even if the facility did not previously exceed the 

threshold. A change to a facility’s reporting status would cause the facility to incur costs for 

monitoring, recordkeeping, and reporting emissions. 

In this memorandum, the impacts of the revised GWPs in Table A-1 to subpart A are 

evaluated on the emissions reported and on the emissions from new reporters that would be 

required to report under each subpart if the changes are incorporated into the reporting rule. The 

compliance costs that would be incurred by these new reporters are also estimated. The 

methodology used to identify the subparts for which emissions calculated as CO2e would change 

is described in section 2.0 of this memorandum. A summary of cost and emissions impacts due 

to the revisions is provided in section 3.0. The methodologies used to determine cost and

emissions impacts to current reporters are described in section 4.0. The methodologies used to 

determine cost and emissions impacts to new reporters are described in section 5.0. 

2.0 IDENTIFICATION OF SUBPARTS AFFECTED BY THE GWP REVISIONS IN 

SUBPART A

2.1 Current Reporters

Current reporters are those reporters that are already affected by the GHG reporting rule 

and have already reported their GHG emissions to e-GGRT (or are expected to report their 

estimated emissions to e-GGRT in the near future). Each GHG source category is identified in 

Table 2-1.

Table 2-1. GHG Reporting Rule Subpart and Source Category

Subpart GHG Source Category

C General Stationary Fuel Combustion Sources

D Electricity Generation 
4

Table 2-1. GHG Reporting Rule Subpart and Source Category

Subpart GHG Source Category

E Adipic Acid Production

F Aluminum Production

G Ammonia Manufacturing

H Cement Production

I Electronics Manufacturing

K Ferroalloy Production

L Fluorinated Gas Production

N Glass Production

O HCFC-22 Production and HFC-23 Destruction

P Hydrogen Production

Q Iron and Steel Production

R Lead Production

S Lime Manufacturing (non-CEMS)

T Magnesium Production

U Miscellaneous Uses of Carbonate

V Nitric Acid Production

W Petroleum and Natural Gas Systems

X Petrochemical Production

Y Petroleum Refineries 

Z Phosphoric Acid Production 

AA Pulp and Paper Manufacturing

BB Silicon Carbide Production 

CC Soda Ash Manufacturing

DD Use of Electric Transmission and Distribution Equipment

EE Titanium Dioxide Production 

FF Underground Coal Mines

GG Zinc Production 

HH Municipal Solid Waste Landfills

II Industrial Wastewater Treatment

JJ Manure Management b

LL Suppliers of Coal based Liquid Fuels

MM Suppliers of Petroleum Products

NN Suppliers of Natural Gas and Natural Gas Liquids

OO Suppliers of Industrial Greenhouse Gases

PP Suppliers of Carbon Dioxide

QQ Importers / Exporters of Equipment Pre-charged with F-GHGs

RR Geologic Sequestration of Carbon Dioxide

SS Manufacture Electric Transmission and Distribution Equipment

TT Industrial Waste Landfills 

UU Injection of Carbon Dioxide

The calculated emissions impacts (due to the revised GWPs) were estimated for current

reporters associated with each of the GHG source categories identified in Table 2-1. The revised
5

GWPs would have no effect on subparts with CO2 as the sole GHG (i.e., subparts MM, NN, PP, 

RR, and UU) because GWP is a measure of the heat trapped by specific gas(es) as compared to 

the heat trapped by CO2. Actual CO2 emissions are not converted to CO2e, and thus GWP has no 

bearing on the emissions or supply in these cases. Similarly, although CO2, CH4, and/or N2O 

combustion emissions are required to be reported for subparts G, R, U, Z, CC, EE, and GG, the 

sole emission type reported under these specific subparts is CO2 process emissions (because 

combustion emissions are required to be reported under subpart C). Therefore, for purposes of 

this memorandum, any change to combustion emissions associated with these subparts is 

incorporated into the impact analysis performed on subpart C; and no other impact (due to the

revised GWPs) is identified for these specific subparts.

The methodology used to determine the impact of the revisions to Table A-1 for current

reporters is presented in section 4.0. 

2.2 New Reporters

New reporters are those reporters that are not affected by the current GHG reporting rule, 

but will become subject to the rule as a result of revisions to the GWPs in Table A-1. Affected 

subparts that might have new reporters due to revised GWPs are those that meet all three of these 

criteria: 1) subpart has a reporting threshold2 and the threshold is based on CO2e, 2) subpart 

requires reporting of emissions of CH4, N2O, or a F-GHG, and 3) EPA estimates that all facilities 

in the subpart did not previously exceed the threshold. The subparts that meet these three criteria 

are subparts I, T, W, HH, II, OO, and TT. The revised GWPs would not create new reporters for 

subparts that have no threshold, because all applicable facilities are already reporting. Similarly, 

categories with thresholds not based on CO2e would not create new reporters resulting from a

revised GWP (e.g., for subpart FF, underground coal mines, the threshold is based on the annual 

volume of methane liberated from a mine). Also, if all facilities in the subpart are currently 

expected to exceed the 25,000 metric tons of CO2e threshold (based on an evaluation of the 

supporting documents for each subpart), then it was assumed that there would be no new 

reporters. In particular, all potential reporters under subparts K, L, and QQ (importers only) are 

estimated to exceed the 25,000 metric tons of CO2e threshold, so no new reporters are expected 

for these subparts due to the new and revised GWPs. For subpart QQ (exporters), all facilities are 

expected to exceed the 25,000 metric tons of CO2e threshold with the exception of exporters of 

SF6 electrical equipment. No additional SF6 equipment exporters are expected to exceed the 

25,000 metric tons of CO2e threshold because the GWP for SF6 is decreasing.

The type of emissions required to be reported by each subpart were also considered. 

Subparts with CO2 as the sole emission type were eliminated; the revised GWPs would not 

 

2 For some subparts, all facilities are required to report.
6

create new reporters for these subparts because GWP is a measure of the heat trapped by specific 

gas(es) as compared to the heat trapped by CO2. Actual CO2 emissions are not converted to 

CO2e, and thus GWP has no bearing on the outputs in these cases. Subparts with emissions 

solely from combustion experienced such small impacts from the GWP revisions that they were 

not expected to trigger any additional reporters. For example, for coal burning, there is only a 

0.024% increase in CO2e as a result of the change to the GWP of CH4 and N2O emissions 

resulting from combustion, and for natural gas, there was only a 0.005% increase. Table 2-2

provides detail for this calculation.

Table 2-2. Example Emission Calculation for 100 Million BTU/hour Combustion Unit -

Comparison of CO2e for Current and Revised GWP

Identifier for 

Methodology

Description and/or

Methodology Anthracite Coal Natural Gas

A CO2 EF (kg CO2/mmBTU) 103.50 53.02

B CH4 EF (kg CH4/mmBTU) 1.10E-02 1.00E-03

C Current GWP for CH4 21

D Revised GWP for CH4 25

E N2O EF (kg N2O /mmBTU) 1.60E-03 1.00E-04

F Current GWP for N2O 310

G Revised GWP for N2O 298

H

Current CH4 CO2e

(B*C)

0.231 0.021

I

Revised CH4 CO2e

(B*D)

0.275 0.025

J

Current N2O CO2e

(E*F)

0.496 0.031

K

Revised N2O CO2e

(E*G)

0.477 0.030

L

Current Total CO2e

(A+H+J)

104.23 53.072

M

Revised Total CO2e

(A+I+K)

104.25 53.075

Percent Change

((M-L)/L)

0.024% 0.005%

For subpart I, facilities that manufacture semiconductors, liquid crystal displays (LCDs), 

and micro-electromechanical systems (MEMS) must calculate annual emissions for threshold 

applicability purposes considering only the gases for which default emission factors are provided 

in Table I-1 to subpart I. Facilities must account for F-HTF emissions as a percentage of the total 

annual production process emissions at a facility (calculated using the default factors in Table I-
7

1). Table I-1 does not include F-GHGs affected by the changes to Table A-1, therefore the 

applicability for these facilities will not change. 

Table 2-3 lists all of the GHG reporting rule subparts and the rationale for including or 

excluding the subpart in the new reporter impact analysis described in section 5.0. As noted in 

Table 2-3 all facilities subject to subparts L and QQ are expected to be above the reporting 

threshold, therefore there are no additional facilities that will be required to report. Emissions of 

fluorinated gases for subpart DD (Use of Electric Transmissions and Distribution Equipment) 

and subpart SS (Electrical Equipment Manufacture) were reported as only SF6 emissions; 

therefore, the assignment of GWPs for other F-GHGs would have no effect on reporters under 

subpart DD and SS. For subpart T (Magnesium Production), the primary gas emitted is SF6.

Because the GWP for SF6 is decreasing, the calculated emissions would decrease, and no 

additional facilities would be required to report as a result. For subpart OO (Industrial GHG 

Suppliers), EPA identified the potential of three additional reporters due to the revisions to the 

GWPs in Table A-1.

Table 2-3. Rationale for GHG Subpart Selection for New Reporter Impact Analysis

Subpart

Excluded / 

Included in New 

Reporter Impact 

Analysis Rationale

C- Stationary Combustion Excluded Combustion emissions only

D- Electricity Generation Excluded Threshold not based on CO2e

E - Adipic Acid Excluded All facilities must report - no threshold

F - Aluminum Excluded All facilities must report - no threshold

G - Ammonia Excluded All facilities must report - no threshold

H - Cement Excluded All facilities must report - no threshold

I - Electronics Included Threshold category that emits mainly fluorinated GHG

K -Ferroalloy Excluded All facilities in subpart expected to be above threshold

L - Fluorinated Gas Excluded All facilities in subpart expected to be above threshold

N - Glass Excluded CO2 and/or combustion emissions only

O - HCFC-22, HFC-23 Excluded Threshold not based on CO2e

P - Hydrogen Excluded CO2 and/or combustion emissions only

Q - Iron & Steel Excluded CO2 and/or combustion emissions only

R - Lead Excluded CO2 and/or combustion emissions only

S - Lime Excluded All facilities must report - no threshold

T - Magnesium Included Threshold category that emits mainly fluorinated GHG

U - Carbonate Excluded CO2 emissions only

V - Nitric Acid Excluded All facilities must report - no threshold

W - Petroleum & Natural Gas Included Threshold category that emits methane 

X - Petrochemicals Excluded All facilities must report - no threshold
8

Table 2-3. Rationale for GHG Subpart Selection for New Reporter Impact Analysis

Subpart

Excluded / 

Included in New 

Reporter Impact 

Analysis Rationale

Y - Refineries Excluded All facilities must report - no threshold

Z - Phosphoric Acid Excluded All facilities must report - no threshold

AA - Pulp & Paper Excluded All facilities in subpart expected to be above threshold

BB - Silicon Carbide Excluded All facilities must report - no threshold

CC - Soda Ash Excluded All facilities must report - no threshold

DD - Electrical Transmission Excluded Threshold not based on CO2e

EE - Titanium Dioxide Excluded All facilities must report - no threshold

FF - Underground Coal Mines Excluded Threshold not based on CO2e

GG - Zinc Excluded CO2 and/or combustion emissions only

HH - MSW Landfills Included Threshold category that emits mostly methane

II - Industrial Wastewater Included Threshold is based on methane generation

JJ - Manure Mgmt Excluded Subpart is not being implemented

LL - Coal-based Liquid Fuels

Suppliers Excluded CO2 is the only GHG reported

MM - Petroleum Suppliers Excluded CO2 is the only GHG reported

NN - Natural Gas Suppliers Excluded Threshold not based on CO2e

OO - Industrial GHG 

Suppliers Included Importers/exporters have threshold for fluorinated GHG 

PP - CO2 Suppliers Excluded CO2 is the only GHG reported

QQ - Importers / Exporters of 

F-gases in pre-charged 

equipment or closed-cell 

foams

Excluded Threshold category and all importers/exporters in the 

category are expected to be above thresholda

RR - Geologic Sequestration Excluded All facilities must report - no threshold

SS - Electrical Equipment Excluded Threshold not based on CO2e

TT - Industrial Waste Landfills Included Threshold is based on methane generation

UU - CO2 Injection Excluded All facilities must report - no threshold

a

Some facilities with SF6 containing electrical equipment were below the threshold; SF6 GWP is decreasing, therefore no 

additional affected facilities.
9

3.0 SUMMARY OF IMPACTS AND SMALL ENTITY IMPACTS – ALL 

REPORTERS

3.1 Summary of Emissions and Cost Impacts

The impacts to the quantity of CO2e reported and costs resulting from the GWP revisions 

for each subpart are presented in two tables: 

 Table 3-1 includes a summary of impacts to the quantity of CO2e reported for all 

reporters; and

 Table 3-2 includes a summary of the cost impacts for the new reporters

anticipated.

These tables include the estimated changes to the number of affected facilities and 

expected CO2e reported.

Table 3-1. 2011 Reporters - Summary of Impacts Due to GWP Revisions for Source Categories 

Reporting in 2011

Subpart

Number of 

Reporters 

Affected by GWP 

Revisionsa

Expected Total 

CO2e Reported 

After GWP 

Revisions

(metric tons CO2e 

per year)b

Total Change in 

CO2e Due to 

GWP Revisions

(metric tons 

CO2e per year)

C –

Stationary Combustion 5,426 618,943,387 145,552 

D –

Electricity Generation 1,258 2,134,344,533 270,863 

E –

Adipic Acid 3 10,200,670 (410,765)

F –

Aluminum 10 7,635,878 170,321

G -

Ammonia 0 14,012,704 0 

H –

Cement 94 52,854,721 4,764 

I –

Electronics 53 3,720,318 593,554 

K –

Ferroalloy 10 2,280,270 1,913 

L –

Fluorinated Gas 16 6,913,066 812,347

N –

Glass 110 2,074,305 4 

O –

HCFC-22, HFC-23 5 8,771,214 1,837,214

P – 103 32,958,021 10 
10

Table 3-1. 2011 Reporters - Summary of Impacts Due to GWP Revisions for Source Categories 

Reporting in 2011

Subpart

Number of 

Reporters 

Affected by GWP 

Revisionsa

Expected Total 

CO2e Reported 

After GWP 

Revisions

(metric tons CO2e 

per year)b

Total Change in 

CO2e Due to 

GWP Revisions

(metric tons 

CO2e per year)

Hydrogen

Q –

Iron & Steel 128 30,664,338 (28)

R –

Lead 0 736,087 0 

S –

Lime 73 16,153,152 162 

T –

Magnesium 9 2,092,420 (96,541)

U –

Carbonate 0 122,216 0 

V –

Nitric Acid 36 10,888,395 (438,459)

W –

Petroleum & Natural Gas 1,646 158,187,220 18,289,767 

X –

Petrochemicals 64 9,302,398 11,872 

Y –

Refineries 145 56,471,884 114,025 

Z –

Phosphoric Acid 0 1,438,428 0 

AA –

Pulp & Paper 110 7,495,513 53,421 

BB –

Silicon Carbide 1 139,994 2,398 

CC –

Soda Ash 0 1,341,446 0 

DD –

Electrical Transmission 97 3,688,839 (177,970)

EE –

Titanium Dioxide 0 1,346,279 0 

FF –

Underground Coal Mines 146 32,896,721 5,263,475 

GG –

Zinc 0 816,621 0 

HH –

MSW Landfills 1,259 109,562,567 2,562,567 

II –

Industrial Wastewater 153 4,499,394 769,883 

JJ –

Manure Mgmt 0 0 0 
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Table 3-1. 2011 Reporters - Summary of Impacts Due to GWP Revisions for Source Categories 

Reporting in 2011

Subpart

Number of 

Reporters 

Affected by GWP 

Revisionsa

Expected Total 

CO2e Reported 

After GWP 

Revisions

(metric tons CO2e 

per year)b

Total Change in 

CO2e Due to 

GWP Revisions

(metric tons 

CO2e per year)

LL –

Coal-based Liquid Fuels Suppliers 0 --

c

0 

MM –

Petroleum Suppliers 0 --

c

0 

NN –

Natural Gas Suppliers 0 --

c

0 

OO –

Industrial GHG Suppliers 170 --

c

44,060,000 

PP –

CO2 Suppliers 0 --

c

0 

QQ –

Importers / Exporters of F-gases in 

pre-charged equipment or closedcell foams

34 --

c

--

d

RR –

Geologic Sequestration 0 0 0 

SS –

Electrical Equipment 5 293,767 (14,173)

TT –

Industrial Waste Landfills 192 10,581,216 2,129,795 

UU –

CO2 Injection 0 --

c

0 

a Includes new reporters who would be required to submit an annual report due to the changes to GWPs in 

Table A-1.

b Expected total CO2e reported includes the change in emissions for existing reporters and from new 

reporters who would be required to submit an annual report due to the changes to GWPs in Table A-1 for 

the source category identified. The expected total CO2e reported does not include emissions from 

reporters who may be required to newly submit an annual report for multiple source categories.

c Not included for subparts for which totals include reporting of CBI.

d Not included for subparts for which totals include reporting of CBI. Assume a nominal 16% increase 

over current CO2e reported. This estimated increase equals the average of the percent change in GWP for 

the HFCs, and PFCs and SF6.
12

Table 3-2. Summary of Cost Impact Due to the GWP Revisions

Subpart

Number of 

New 

Reporters 

Due to GWP 

Revisions

Incremental CO2e 

for New Reporters 

(metric tons CO2e 

per year)

First Year

Cost Impact

($/yr)

Incremental Cost 

Impact 

($/yr)

I –

Electronics 4 18,076 129,500 237,000

T –

Magnesium 0 0 0 0

W –

Petroleum & 

Natural Gas

99 2,572,881 1,648,000 772,000

HH –

MSW Landfillsa 57 1,560,000 246,000 182,200

II –

Industrial 

Wastewater

2 59,500 10,800 10,500

OO –

Industrial GHG 

Suppliers

3 75,000 13,100 10,000

TT –

Industrial Waste

Landfillsa

19 520,000 112,000 98,050

Total 184 4,805,457 2,195,400 1,316,750

a Subpart HH cost impact includes average annualized reporting costs for 43 closed landfills that will exit the 

reporting program later than expected. Similarly, subpart TT cost impact includes average annualized costs for 8 

closed facilities.

3.2 Small Entity Impacts

There will be a cost impact of the change to GWP for new reporters and for closed 

landfills that will be required to remain in the program for a longer period of time; the cost of 

reporting will not significantly change for those entities already required to report. A detailed 

discussion of the cost impact to small entities is included in the individual subpart analyses for

new reporters in section 5.0. For each affected subpart that may have new reporters due to the 

revised GWPs, information available in supporting documents was used to identify the small 

businesses affected, and an impact evaluation was performed. For each subpart evaluated, it was 

determined that there is not a significant impact on a substantial number of small businesses.

4.0 METHODOLOGY FOR ESTIMATING IMPACTS TO CURRENT REPORTERS

4.1 Emissions Impacts (current reporters)

The level of increased calculated CO2e that will be reported by existing reporters (due to 

the revised GWPs) was estimated by adjusting the 2011 reported GHG emissions using the new 

GWP for each reported compound. The reported emissions of each GHG (CO2, CH4, N2O, etc.) 
13

were extracted from the most recent data reported to EPA (US EPA 2013a). The total number of 

facilities reporting under each subpart was defined and the total reported emissions of each GHG 

for each subpart were calculated. The total reported mass emissions of each GHG were 

multiplied by the current GWP (see 40 CFR part 98, subpart A, Table A-1) to determine the 

original reported emissions of each GHG in metric tons of CO2e. To calculate the emissions 

impacts in metric tons of CO2e (due to the revised GWPs) for each source category, the mass 

emissions for each GHG were multiplied by the difference between the existing GWP and the 

revised GWPs from the IPCC AR4. For some subparts, Table 3-1 shows no change in the 

expected CO2e reported emissions from the changes to the GWPs. Although CO2, CH4, and N2O 

combustion emissions are required to be reported for subparts G, R, U, Z, CC, EE, and GG, the 

sole emission type reported under these specific subparts is CO2 process emissions (because 

combustion emissions are required to be reported under subpart C and there are no CH4 or N2O 

process emissions for these subparts). Therefore, for purposes of this analysis, any change to 

combustion emissions associated with these subparts is incorporated into the impact analysis 

performed on subpart C; and no other impact (due to the revised GWPs) is identified for these 

specific subparts.

For several subparts that report fluorinated gases, emissions information was not 

available for the individual compounds. Emissions estimates for these subparts are discussed in 

more detail in sections 4.1.1 and 4.1.2. 

4.1.1 Subpart I Emissions Impacts (current reporters)

In the original threshold analysis (U.S. EPA, 2010a), EPA identified the number of 

facilities that would be covered under subpart I with a 25,000 metric tons CO2e emissions-based 

threshold. For LCDs and PVs, EPA calculated the total annual emissions, in metric tons of CO2e, 

for each facility using the IPCC Tier 1 default emissions factors. The emissions factors were 

converted to metric tons of CO2e basis by multiplying the factors by the appropriate GWP value. 

EPA used the results to estimate the magnitude of emissions from those facilities expected to 

emit greater than the 25,000 metric tons CO2e threshold. The number of, and emissions from, 

MEMS facilities were calculated using the same procedure, but with an emission factor 

developed by the EPA (U.S. EPA, 2010b). 

In the original analysis, EPA used the same procedure described above (i.e., default IPCC 

Tier 1 factors) to determine the number of semiconductor facilities that were expected to emit 

greater than the 25,000 metric tons CO2e threshold. To estimate the magnitude of emissions from 

those semiconductor facilities expected to emit greater than the threshold, EPA used emission 

estimations that were derived using outputs from the EPA PFC Emissions Vintaging Model 

(PEVM), as well as the EPA PFC Reduction/Climate Partnership for Semiconductors partner and 

non-partner shares of U.S. emissions. EPA also accounted for heat transfer fluid emission 
14

estimates by assuming such emissions were equal to 11 percent of total clean and etch emissions 

at a facility. 

To determine the level of increased emissions that will be reported by existing reporters 

under subpart I due to the revised GWPs, the methodology from EPA’s original threshold 

analysis was followed, but with the updated GWP values. The PEVM was not accessible to 

reproduce the original emission estimates; therefore, it was assumed that the PEVM based 

emissions would increase by the same percentage as the emissions estimated using the IPCC 

Tier 1 default factors and updated GWP values. This is a valid assumption because no other 

inputs to the PEVM are expected to change. The overall increase in emissions for this subpart is 

estimated at approximately 18.4 percent above the 2011 reported emissions.

4.1.2 Subpart L and QQ Emissions Impacts (current reporters)

Because there are 17 different fluorinated compounds for which the GWP will change by

varying amounts, and a breakdown of emissions by compound was not available for subpart L or 

QQ, a nominal 16 percent increase was estimated as the expected increase in emissions due to 

revised GWPs for SF6, HFCs, and PFCs. This estimated increase equals the average of the 

percent change in GWP for the HFCs, and PFCs and SF6 for compounds listed in Table A-1.

4.2 Cost Impacts (current reporters)

For reporters that currently are subject to the rule for reporting, there would be no

significant cost impacts resulting from the revised GWPs, with the exception of landfills 

expected to close after 2014 for subparts HH and TT (see the discussion in section 5.4 and 

section 5.7 for subpart HH and TT, respectively). Although some affected facilities and suppliers 

would report higher CO2e emissions in their annual GHG report, using the revised GWPs would 

not affect the cost of monitoring and recordkeeping and would not materially affect the cost for 

calculating emissions.

4.3 References for Section 4.0

U.S. EPA, 2013a. 2011 Greenhouse Gas Reporting Program Data ( reported to EPA by facilities as of 

February 17, 2013).

U.S. EPA, 2012b. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2010, April 2012. 

http://epa.gov/climatechange/Downloads/ghgemissions/US-GHG-Inventory-2012-Main-Text.pdf

U.S. EPA, 2010a. Subpart I Detailed Threshold Analysis. See Docket ID: EPA-HQ-OAR-2009-0927-

0158. November 2010.

U.S. EPA, 2010b. Technical Support Document for Process Emissions from Electronics Manufacture 

(e.g., Micro-Electro-Mechanical Systems, Liquid Crystal Displays, Photovoltaics, and Semiconductors): 

Proposed Rule for Mandatory Reporting of Greenhouse Gases. Revised November 2010. Available at: 

http://www.epa.gov/climatechange/emissions/downloads10/Subpart-I_TSD.pdf
15

5.0 METHODOLOGY FOR ESTIMATING IMPACTS TO NEW REPORTERS

The methodologies used to determine cost and emissions impacts to new reporters (due to

the revised GWPs in Table A-1 to subpart A) are described in this section. Summaries of the 

methodology, reference documents, and any assumptions specific to each subpart (that are 

identified as not currently being affected by the GHG reporting rule, but will become subject to 

the rule as a result of revisions to the GWPs in Table A-1) are documented in the following 

individual subpart subsections. Each of these individual subpart subsections are further organized 

into smaller sections that discuss the following topics: identifying new reporters; estimating 

emissions impacts; estimating cost impacts; small entities impacts; summary of impacts; and 

references.

5.1 Subpart I 

Subpart I requires reporting of fluorinated GHGs from the following source categories

that emit 25,000 metric tons CO2e per year or more: electronics manufacturing including 

manufacture of semiconductors, PVs, LCDs, and MEMS. Changes to the following GWPs affect 

subpart I: CF4, C2F6, CHF3, C3F8, SF6, C6F14 (semiconductors); SF6 (MEMS); CF4, SF6 (LCDs); 

and CF4, C2F6 (PVs). As discussed in section 2.2, subpart I reporters must calculate annual 

emissions for threshold applicability purposes considering only the gases for which default 

emission factors are provided in Table I-1. Although facilities must also account for F-HTF 

emissions, these emissions are estimated as a percentage of the total annual production process 

emissions at a facility (calculated based on gases in Table I-1).

5.1.1 Subpart I (identifying new reporters)

In the original threshold analysis (U.S. EPA, 2010a), EPA identified the number of 

facilities that would be covered under subpart I with a 25,000 metric tons CO2e emissions-based 

threshold. The original threshold analysis included a list of facilities for each product type (i.e., 

semiconductors, MEMS, LCDs, and PVs) and estimates of substrate area processed and total 

annual emissions for each facility. 

For LCDs and PVs, EPA calculated the total annual emissions, in metric tons of CO2e, 

for each facility using the IPCC Tier 1 default emissions factors. The emissions factors were 

converted to metric tons of CO2e basis by multiplying the factors by the appropriate GWP value. 

EPA evaluated the results to determine which facilities were expected to emit greater than the 

25,000 metric tons CO2e threshold. EPA also used the results to estimate the magnitude of 

emissions from those facilities expected to emit greater than the 25,000 metric tons CO2e

threshold. The number of, and emissions from, MEMS facilities were calculated using the same 

procedure, but with an emission factor developed by the EPA (U.S. EPA, 2010b). 
16

In the original threshold analysis, EPA used the same procedure described above (i.e., 

default IPCC Tier 1 factors) to determine the number of semiconductor facilities that were 

expected to emit greater than the 25,000 metric tons CO2e threshold. EPA did not consider 

emissions from heat transfer fluids when determining which semiconductor facilities would meet 

the threshold. To estimate the magnitude of emissions from those semiconductor facilities 

expected to emit greater than the threshold, EPA used emission estimations that were derived 

using outputs from the EPA PEVM, as well as the EPA PFC Reduction/Climate Partnership for 

Semiconductors partner and non-partner shares of U.S. emissions. EPA also accounted for heat 

transfer fluid emission estimates by assuming such emissions were equal to 11 percent of total 

clean and etch emissions at a facility. 

To determine the additional number of facilities that would meet the threshold due to 

changes to the GWP values in subpart A, the methodology from EPA’s original threshold 

analysis was followed, but with the updated GWP values. The PEVM was not accessible to 

reproduce the original emission estimates; therefore, it was assumed that the PEVM based 

emissions would increase by the same percentage as the emissions estimated using the IPCC 

Tier 1 default factors and updated GWP values. This is a valid assumption because no other 

inputs to the PEVM are expected to change. 

Table 5-1 identifies the number of new subpart I reporters that will become subject to the 

rule as a result of revisions to the GWPs in Table A-1.

Table 5-1. New Subpart I Reporters

Facility Type Number of New Reporters Due to 

GWP Revisions

Large Semiconductor 0

Non-Large Semiconductor 4

Non-Semiconductor 0

Total 4

5.1.2 Subpart I (estimating emissions impacts)

An emissions increase would be expected from new subpart I reporters that will become 

subject to the rule as a result of revisions to the GWPs in Table A-1. This emissions increase was 

determined using the methodology from EPA’s original threshold analysis (U.S. EPA, 2010a), 

but with the updated GWP values. It was assumed that the PEVM-based emissions would 

increase by the same percentage as the emissions estimated using the IPCC Tier 1 default factors 

and updated GWP values. Table 5-2 identifies the emissions impact from new subpart I 

reporters.
17

Table 5-2. Emissions Impact From New Subpart I Reporters

Facility Type Incremental CO2e Emissions for New Reporters

(metric tons of CO2e per year )

Large Semiconductor -

Non-Large Semiconductor 18,100

Non-Semiconductor -

Total 18,100

5.1.3 Subpart I (estimating cost impacts)

Costs were calculated by multiplying the average costs per facility and the number of 

new facilities estimated to be subject to subpart I (from revising the GWPs). Average costs per 

facility were calculated by dividing total cost by the number of respondents identified in the most 

recent information collection request for the GHG reporting program (U.S. EPA, 2013). 

Appendices J and L to the most recent information collection request for the GHG 

reporting program (U.S. EPA, 2013) were used to obtain first year average cost per facility that 

is incurred from reporting under subpart I. Cost details from Exhibit 6.1 of the most recent 

information collection request for the GHG reporting program (U.S. EPA, 2013) were used to 

determine the subsequent years average cost per facility. These average costs per facility include 

labor costs (i.e., the cost of labor by facility staff to meet the rule’s information collection 

requirements) and non-labor (capital, and operation and maintenance) costs. Additional details of 

the data, methods, and assumptions underlying these costs are documented in the most recent 

information collection request (U.S. EPA, 2013).

Table 5-3 shows first and subsequent year average cost per facility subject to subpart I.

Table 5-3. Annual Average Cost Per Facility Subject to Subpart I

Subpart

Total Number 

of 

Respondents a

Total Cost

(2011$ per year)

Cost Per Facility

(2011$ per year)

First Year b Subsequent 

Years a First Year b Subsequent Years a

I –

Electronics 94 3,042,000 5,567,000 32,400 59,200

a This data was extracted from Exhibit 6.1 of the Supporting Statement Part A: Information Collection Request For 

The Greenhouse Gas Reporting Program (U.S. EPA, 2013). EPA is currently updating certain provisions of subpart 

I. Those updates are reflected in the ICR for that rulemaking effort.

b The first year total cost are from the current cost & burden table identified as “First-Year Burden & Cost” in 

Appendix J-3 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas 

Reporting Program (U.S. EPA, 2013) and includes $80.91 from the current burden & cost table identified as “First 

Reporting Year” table of Appendix L-2 of the Supporting Statement Part A: Information Collection Request For The 

Greenhouse Gas Reporting Program (U.S. EPA, 2013). The $80.91 is the cost contributed to provisions of 

information on parent companies, NAICS codes, and whether emissions are from cogeneration. These costs were 

updated to 2011 dollars using the Bureau of Labor Statistics Employment Cost Index and the Chemical Engineering 

Plant Cost Index (CEPCI). 
18

By revising the GWP values in subpart A, four additional non-large semiconductor 

facilities will be required to report under subpart I. The first year cost for these four facilities will 

be approximately $129,500 per year (4 x $32,365 = $129,500), and the annualized industry wide 

cost is approximately $237,000 per year (4 x $59,200 = $236,800).

Because EPA has recently published the “Final Amendments and Confidentiality

Determinations for Subpart I” (signed by the Administrator on August 16, 2013), it is assumed 

that the costs presented above are overly conservative. The final amendments to subpart I are 

expected to reduce the cost to reporters. The updated costs for subpart I have been submitted for 

approval to the Office of Management and Budget.

5.1.4 Subpart I Small Entity Impacts (new reporters)

In the subpart I Economic Impact Analysis (U.S. EPA, 2010c), EPA originally assessed 

the impact of complying with subpart I requirements on all small entities in the electronics 

manufacturing industry by calculating a cost-to-sales ratio for six enterprise size ranges (i.e., 1 to 

20 employees, 20 to 99 employees, 100 to 499 employees, 500 to 749 employees, 750 to 999 

employees, and 1,000 to 1,499 employees) using the average total annualized mandatory

reporting costs to the average annual sales receipts for each establishment. The results of this 

analysis are represented in Table 14 of the preamble for the publication of the subpart I rule (75 

FR 74811, December 1, 2010).

Based on this analysis, EPA concluded that subpart I will not have a significant economic 

impact on a substantial number of small entities (U.S. EPA, 2010c)3. EPA made this 

determination assuming that all entities in the industry would report (including those above and 

below the reporting threshold), resulting in a conservatively high analysis. EPA determined that 

no significant small business economic impacts were expected to occur. The analysis showed 

that the cost-to-sales ratio for all entity sizes except for the smallest sized enterprises was less 

than 1 percent. EPA concluded that although the cost-to-sales ratio for the 1 to 20 employee 

range for semiconductor and related device manufacturing was greater than one percent (i.e., 

1.16 percent); facilities with emissions greater than 25,000 metric tons CO2e per year are 

unlikely to be included in the 1 to 20 employees size category (U.S. EPA, 2010c). 

The revised emission estimates (using the revised GWPs) place the 4 new affected 

facilities above the 25,000 metric tons CO2e threshold. In addition, the emission estimates for the 

4 facilities in the original threshold analysis were just slightly below the threshold (3 to 10 

percent). Based on EPA’s conclusion that facilities with emissions greater than 25,000 metric 

tons CO2e per year are unlikely to be included in the 1 to 20 employees size category, the 4 

 

3 Refer to Section 5.3 of the 2010 EIA (U.S. EPA, 2010a). 
19

additional facilities are not expected to be included in the 1 to 20 employees size category either. 

As a result, the changes to the GWPs will not have a significant impact on a substantial number 

of small entities.

5.1.5 Subpart I (summary of impacts)

Table 5-4 summarizes the impacts of updating the GWP values in Table A-1 to subpart 

A, on new facilities required to report subpart I emissions.

Table 5-4. New Reporters—Summary of Subpart I Impacts Due to the Revisions to GWPs

Facility Type

Number of New 

Reporters Due 

to GWP 

Revisions

Incremental 

CO2e Emissions 

for New 

Reporters

(metric tons of 

CO2e per year ) a

Incremental Cost Impact For New 

Reporters

(2011$ per year)

First Year a Subsequent 

Years a

Large Semiconductor 0 - - -

Non-Large Semiconductor 4 18,100 129,600 237,000

Non-Semiconductor 0 - - -

Total 4 18,100 129,600 237,000

a Values rounded.

5.1.6 References for Subpart I

U.S. EPA, 2010a. Subpart I Detailed Threshold Analysis. See Docket ID: EPA-HQ-OAR-2009-0927-

0158. November 2010.

U.S. EPA, 2010b. Technical Support Document for Process Emissions from Electronics Manufacture 

(e.g., Micro-Electro-Mechanical Systems, Liquid Crystal Displays, Photovoltaics, and Semiconductors): 

Proposed Rule for Mandatory Reporting of Greenhouse Gases. See Docket ID: EPA-HQ-OAR-2009-

0927-0195. Revised November 2010.

U.S. EPA, 2010c. Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions 

F-Gases: Subparts I, L, DD, QQ, SS Final Report. See Docket ID: EPA-HQ-OAR-2009-0927-0179. 

November 2010.

U.S. EPA, 2013. Supporting Statement Part A: Information Collection Request For The Greenhouse Gas 

Reporting Program. OMB Control No. 2060-0629. EPA ICR No. 2300.10. May 2013.

5.2 Subpart T 

Magnesium production and processing facilities are defined as any site where magnesium 

metal is produced through smelting (including electrolytic smelting), refining, or remelting 

operations, or any site where molten magnesium is used in alloying, casting, drawing, extruding, 

forming, or rolling operations. Each facility must report total annual emissions for each of the 

following cover or carrier gases used in magnesium production or processing: SF6, HFC-134a, 

the fluorinated ketone FK 5-1-12, CO2, and any other fluorinated GHG as defined in the 

greenhouse gas reporting rule. 
20

5.2.1 Subpart T (identifying new reporters)

In the 2010 Threshold Analysis for the magnesium production category for the original 

rule (U.S. EPA, 2009), EPA identified 13 nationwide facilities in the magnesium production and 

processing source category. EPA evaluated a range of threshold options for these facilities, 

utilizing 2006 annual reporting data on metal production and SF6 consumption provided through 

the EPA’s SF6 Emission Reduction Partnership for the Magnesium Industry as the basis for the 

analysis. These included emission-based thresholds of 1,000, 10,000, 25,000 and 100,000 metric 

tons CO2e, as shown in Table 5-5, and capacity-based thresholds equivalent to these. The July

12, 2010 final rule established an emissions threshold of 25,000 metric tons CO2e, which was 

estimated to cover all currently operating U.S. primary and secondary magnesium ingot 

producers and most die casters, accounting for over 99 percent of emissions from these source 

categories. This threshold analysis excluded small die casting facilities as well as facilities that 

performed other types of casting, which represent only a small fraction of total emissions from 

this source category. The emissions threshold of 25,000 metric tons CO2e established in the final 

rule was equal to emissions of 1,046 kg of SF6; 19,231 kg of HFC–134a; or 25,000,000 kg of 

CO2 (based on the GWP values established in Table A-1 to subpart A of part 98) (U.S. EPA, 

2009).

Table 5-5. Threshold Analysis for Subpart T – Magnesium Production

Emission 

Threshold 

Level (metric 

tons 

CO2e/yr)

Total 

National 

Emissions

(metric tons 

CO2e/yr)

Total 

Number of 

Facilities

Emissions Covered Facilities Covered

metric tons 

CO2e/yr Percent Facilities Percent

1,000 3,200,000 13 2,954,559 92% 13 100.0%

10,000 3,200,000 13 2,939,741 92% 11 85.0%

25,000 3,200,000 13 2,939,741 92% 11 85.0%

100,000 3,200,000 13 2,872,982 90% 9 69.0%

Facility-level information from the threshold analysis for the 2010 final rule was not 

published in Docket No. EPA–HQ–OAR–2008–0508 due to confidentiality concerns. Therefore, 

for purposes of this memorandum, the incremental impacts to the magnesium production 

industry were estimated based on the available aggregate data. In order to estimate the source 

category impacts from revising the GWPs in Table A-1 to subpart A of part 98, the 2004 GWPs 

reflected in Table A-1 to subpart A were compared to the revised GWPs to determine the 

increase for each reported pollutant. 

Only SF6 and HFC-134a have been evaluated for the purposes of estimating the impacts 

of the revised GWPs. Table 5-6 lists the pollutants and associated increase in GWP for each 

chemical. Emissions of the fluorinated ketone FK 5–1–12, although required to be reported 
21

under 40 CFR 98.202, are not included in this threshold analysis, because this gas has a GWP of 

1.8 and is not expected to significantly impact reported emissions. 

Table 5-6. Increase in GWP for Pollutants Associated with 

Magnesium Production and Processing

Pollutant Name CAS No. Chemical formula

GWP in Table A1 of the final rule New GWP % Increase

FK-5-1-12 756-13-8 C3F7C(O)C2F5 NA 1.8 -

HFC–134a 811–97–2 CH2FCF3 1,300 1,430 10

SF6 2551–62–4 SF6 23,900 22,800 -5

As shown in Table 5-6, emissions from facilities utilizing SF6 that meet the current 

25,000 metric tons CO2e threshold would decrease as a result of the revised GWP for SF6. For 

these facilities, this decrease would be significant only if the revisions to the GWP reduced their 

annual emissions to less than 25,000 metric tons CO2e for 5 consecutive years (per 40 CFR 

98.2(i)). Therefore, the impacts of these emissions reductions were not assessed in this 

memorandum. Facilities utilizing the cover gas HFC-134a could potentially become subject to 

the GHG reporting rule if the increase in the GWP brought facility-wide emissions above 25,000 

metric tons CO2e. This would include only facilities with current total facility emissions between 

22,500 metric tons CO2e and 25,000 metric tons CO2e. 

The aggregate data from the 2010 Threshold Analysis showed that the 11 facilities 

exceeding the 10,000 metric tons CO2e threshold also exceeded the 25,000 metric tons CO2e

threshold (see Table 5-5). Based on these data, there would be no facilities meeting the 10,000 

metric tons CO2e threshold that would be affected by the revised GWPs, because these facilities 

already exceed the 25,000 metric tons CO2e threshold. Only two facilities not meeting the 25,000 

metric tons CO2e threshold could potentially be affected by an increase in the GWPs; these two 

facilities did not exceed the 10,000 metric tons CO2e threshold at the time subpart T was 

finalized in July 2010, therefore it is unlikely that these facilities would exceed 25,000 tons CO2e 

per year with the GWP change.

Updated data from the SF6 Emission Reduction Partnership program4for the 2010 

reporting year were used to verify the conclusion that no additional facilities will be impacted by

the revised GWPs. EPA operated the SF6 Emission Reduction Partnership to encourage industry

to reduce emissions of SF6 and eliminate the usage of SF6 as a cover gas. As a result, facilities 

have increased usage of FK 5–1–12 (proposed GWP=1.8) and HFC-134a (proposed 

GWP=1,430) as cover gases, resulting in an overall reduction in industry GHG emissions. 

Facilities reporting under the SF6 Emission Reduction Partnership include major emitters. Non-

 

4 See EPA’s SF6 Emission Reduction Partnership for the Magnesium Industry at: 

http://www.epa.gov/highgwp/magnesium-sf6/index.html
22

reporting facilities include smaller facilities (e.g., sand casting or small die casters) whose 

emissions are expected to be less than the threshold reporting level. The Partnership data is 

limited because not all facilities consistently report gas use each year; additionally, process data 

reported under the Partnership has historically been considered confidential. For this analysis, 

only aggregate facility-level emissions based on SF6 usage were available; emissions data from 

other gas usage were not available. Based on the 2010 SF6 Partnership data, 16 facilities 

reported, and 11 facilities reported use of SF6. This is close to the original estimate of 13 

processing facilities in the 2010 Threshold Analysis, which was based on 2006 emission 

estimates. The reported 2010 SF6 emissions are summarized in Table 5-7.

Table 5-7. 2010 SF6 Emissions Reported through the SF6 Partnership

Total Number of 

Facilities

SF6 Emissions Level 

(metric tons CO2e/yr)

Facilities Meeting SF6 Emission 

Level

16

0-999 16

1,000-9,999 11

10,000-22,499 9

22,500-24,999 9

25,000-99,999 7

>100,000 3

For the purposes of this analysis, it was assumed that the 11 facilities reporting SF6 usage 

through the EPA’s SF6 Magnesium Partnership are using FK 5–1–12, HFC-134a, or alternative 

cover gases in addition to the SF6 reported. Five facilities reported no emissions of SF6; these 

facilities are assumed to have used only alternative gases, such as HFC-134a or FK 5–1–12, for 

all production in 2010. Total SF6 emissions reported through the Partnership showed a 67% 

reduction in emissions from 2006. Based on the Inventory of U.S. Greenhouse Gas Emissions 

and Sinks: 1990-2012 (U.S. EPA, 2012), emissions of SF6 from magnesium production and 

processing in the United States were estimated to be 1.3 million metric tons CO2e in 2010, a 

reduction from 3.2 million metric tons CO2e in 2006. Therefore, it is anticipated that the 

emissions estimates summarized in Table 5-7 are a reasonable representation of gas usage in the 

industry following the 2010 Threshold Analysis.

There is no available data on the total gas consumption of the alternative cover gases 

HFC-134a or FK-5-1-12. However, the field of potential reporters was examined to determine if 

it could be affected if HFC-134a usage were increased. Without data on HFC-134a usage, it is 

unclear whether the five facilities that did not report SF6 emissions to the SF6 Partnership 

currently exceed or could exceed the 25,000 metric tons CO2e threshold. However, because the 

GWPs of HFC-134a (new GWP=1,430) and FK-5-1-12 (proposed GWP=1.8) are significantly

lower than that of SF6 (new GWP = 22,800), facilities converting production gases entirely from 

SF6 to entirely HFC-134a or FK-5-1-12 would need to use significantly more cover gas to 
23

exceed the threshold. For example, a facility would need to use approximately 16 times more 

HFC-134a as a cover gas in production to meet the 25,000 metric tons CO2e threshold than if SF6

were used. Furthermore, the 2010 Partnership Data show the largest-emitting facility to have 

maximum SF6 emissions of ~386,000 metric tons CO2e. Assuming that total gas usage rates 

remained the same, if this facility were to convert all production gases to HFC-134a, the 

maximum GHG emissions would be just under the 25,000 metric tons CO2e threshold (386,000 * 

[1,430/22,800] = 24,200). Similarly, if this facility were to convert all production gases to FK-5-

1-12, the maximum GHG emissions would under 31 metric tons CO2e (386,000 *[1.8/22,800]=

30.5). Therefore, facilities utilizing the cover gas FK-5-1-12 are unlikely to exceed the 25,000 

metric tons CO2e threshold. Therefore, it is anticipated that the remaining facilities do not likely

use sufficient HFC-134a or FK-5-1-12 to meet or exceed the 25,000 metric tons CO2e threshold, 

and the total number of facilities required to report would not be affected due to the revised 

GWPs. The total number of facilities reporting under subpart T is expected to decrease over time 

due to the conversion of cover gas from SF6 to HFC-134a or FK 5–1–12. 

Table 5-8 identifies the number of new subpart T reporters that will become subject to the 

rule as a result of revisions to the GWPs in Table A-1.

Table 5-8. New Subpart T Reporters

Facility Type Number of New Reporters Due to 

GWP Revisions

T –

Magnesium 0

5.2.2 Subpart T (estimating emissions impacts)

Because there are no new facilities anticipated to be affected by the revised GWPs, there 

is no emissions impact from new subpart T reporters. Table 5-9 identifies the emissions impact 

from new subpart T reporters.

Table 5-9. Emissions Impact From New Subpart T Reporters

Facility Type Incremental CO2e Emissions for New Reporters

(metric tons of CO2e per year )

T –

Magnesium 0

5.2.3 Subpart T (estimating cost impacts)

Costs were calculated by multiplying the average costs per facility and the number of 

new facilities estimated to be subject to subpart T (from revising the GWPs). Average cost per 

facility for the first year was calculated by dividing total cost by the number of respondents 

identified in the initial information collection request for subpart T (U.S. EPA, 2010). Average 
24

cost per facility for subsequent years was calculated by dividing total cost by the number of 

respondents identified in the most recent information collection request for the GHG reporting 

program (U.S. EPA, 2013). 

Appendix A to the initial information collection request for subpart T (U.S. EPA, 2010) 

was used to obtain first year average cost per facility that is incurred from reporting under 

subpart T. Cost details from Exhibit 6.1 of the most recent information collection request for the 

GHG reporting program (U.S. EPA, 2013) were used to determine the subsequent years average 

cost per facility. These average costs per facility include labor costs (i.e., the cost of labor by 

facility staff to meet the rule’s information collection requirements) and non-labor (capital, and 

operation and maintenance) costs. Additional details of the data, methods, and assumptions 

underlying these costs are documented in the information collection requests (U.S. EPA, 2010 

and U.S. EPA, 2013).

Table 5-10 shows first and subsequent year average cost per facility subject to subpart T.

Table 5-10. Annual Average Cost Per Facility Subject to Subpart T

Subpart

Total Number 

of 

Respondents a

Total Cost

(2011$ per year)

Cost Per Facility

(2011$ per year)

First Year b Subsequent 

Years a First Year b Subsequent Years a

T –

Magnesium 11 123,000 124,000 11,100 11,300

a This data was extracted from Exhibit 6.1 of the Supporting Statement Part A: Information Collection Request For 

The Greenhouse Gas Reporting Program (U.S. EPA, 2013).

b This data was extracted from the “Year 1” table of Appendix A to the initial information collection request for 

subpart T (U.S. EPA, 2010). These costs were updated to 2011 dollars using the Bureau of Labor Statistics 

Employment Cost Index and the Chemical Engineering Plant Cost Index (CEPCI).

The change of GWP for HFC-134a from 1,300 to 1,400, the change of GWP for SF6 from 

23,900 to 22,800, and the proposed, but not finalized, addition of a GWP of 1.8 for FK-5-1-12 is 

not anticipated to result in additional facilities subject to subpart T. Therefore, there are no 

significant rule implementation costs associated with the amendment (0 x $11,272 = $0).

5.2.4 Subpart T Small Entity Impacts (new reporters)

Since it is estimated that no new subpart T entities will be required to report as a result of 

revisions to the GWPs in Table A-1, it is anticipated that there is not a significant impact on a 

substantial number of small entities subject to reporting under subpart T as a result of this action.

5.2.5 Subpart T (summary of impacts)

Table 5-11 summarizes the impacts of updating the GWP values in Table A-1 to subpart 

A, on new facilities required to report subpart T emissions.
25

Table 5-11. New Reporters—Summary of Subpart T Impacts Due to the Revisions to GWPs

Facility Type

Number of New 

Reporters Due to 

GWP Revisions

Incremental CO2e 

Emissions for New 

Reporters

(metric tons of 

CO2e per year )

Incremental Cost 

Impact For New 

Reporters

(2011$ per year)

T –

Magnesium 0 0 0

5.2.6 References for Subpart T

U.S. EPA, 2009. Additional Methodological Information Supporting Threshold Analysis for Specific 

Source Categories. See Docket ID No. EPA-HQ-OAR-2008-0508-0046. March 2009.

U.S. EPA, 2010. Supporting Statement Part A: Information Collection Request for the Mandatory 

Reporting of Greenhouse Gases from Magnesium Production, Underground Coal Mines, Industrial 

Wastewater Treatment, and Industrial Waste Landfills – Final Rule. OMB Control No. 2060-0647. EPA 

ICR No. 2396.01. July 2010.

U.S. EPA, 2012. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2012. April 15, 2012. 

USEPA #430-R-12-001.

U.S. EPA, 2013. Supporting Statement Part A: Information Collection Request For The Greenhouse Gas 

Reporting Program. OMB Control No. 2060-0629. EPA ICR No. 2300.10. May 2013. 

5.3 Subpart W 

Subpart W requires petroleum and natural gas facilities to report annual CH4, CO2, and 

N2O emissions from specific source types that are dependent upon the industry segment. The 

industry segments include: NG Processing, NG Transmission, Underground NG Storage, LNG 

Storage, LNG Import/Export, NG Distribution, Onshore Production, and Offshore Production.

5.3.1 Subpart W (identifying new reporters)

The facility and source specific emissions data used to develop the subpart W Economic 

Impact Analysis (U.S. EPA. 2010) was used to identify the additional subpart W facilities that 

may be required to report using the revised GWPs.

Subpart W requires emissions reporting for CO2, CH4, and N2O; therefore, the 

incremental cost impacts due to the revised GWP were evaluated for only these compounds. The 

GWP for CO2 remains the same. The GWP for CH4 is increasing by 19%. The GWP for N2O is 

decreasing by 4%. These GWP changes were applied to the source specific emissions data for 

each subpart W facility to identify the additional facilities that would be required to report under 

the new GWPs. Table 5-12 identifies the number of new subpart W reporters (for each subpart 

W industry segment) that will become subject to the rule as a result of revisions to the GWPs in 

Table A-1.
26

Table 5-12. New Subpart W Reporters by Industry Segment

Subpart W Industry Segment

Number of New Reporters Due to GWP 

Revisions

NG Processing 2

NG Transmission 7

Underground NG Storage 6

LNG Storage 2

LNG Import/Export 0

NG Distribution 16

Onshore Production 52a

Offshore Production 14

Total (8 Segments) 99

a Conservatively assumes that all emissions related to non-combustion sources are methane, and all emissions related to 

combustion sources are carbon dioxide.

5.3.2 Subpart W (estimating emissions impacts)

Table 5-13 identifies the emissions impact from new subpart W reporters by industry

segment. The emissions estimates are based on the facility and source specific emissions data 

used to develop the subpart W Economic Impact Analysis (U.S. EPA. 2010). For LNG storage 

and NG distribution, the incremental expected emissions were estimated to be 450,000 metric 

tons CO2e by calculating the number of new facilities in these two industry segments (2+16 = 

18) by 25,000 metric tons CO2e because it was assumed these facilities would only just meet the 

25,000 metric tons CO2e reporting threshold.

Table 5-13. Emissions Impact From New Subpart W Reporters 

Subpart W Industry Segment

Incremental CO2e Emissions for New Reporters

(metric tons of CO2e per year )

NG Processing 52,067

NG Transmission 177,091

Underground NG Storage 158,286

LNG Storage 50,000

LNG Import/Export 0

NG Distribution 400,000

Onshore Production 1,372,641

Offshore Production 362,796

Total (8 Segments) 2,572,881

5.3.3 Subpart W (estimating cost impacts)

Costs were calculated by multiplying the average costs per facility and the number of 

new facilities estimated to be subject to subpart W (from revising the GWPs). Average costs per 
27

facility were calculated by dividing total cost by the number of respondents identified in the most 

recent information collection request for the GHG reporting program (U.S. EPA, 2013). 

Appendices I and L to the most recent information collection request for the GHG 

reporting program (U.S. EPA, 2013) were used to obtain first year average cost per facility that 

is incurred from reporting under subpart W. Cost details from Exhibit 6.1 of the most recent 

information collection request for the GHG reporting program (U.S. EPA, 2013) were used to 

determine the subsequent years average cost per facility. These average costs per facility include 

labor costs (i.e., the cost of labor by facility staff to meet the rule’s information collection 

requirements) and non-labor (capital, and operation and maintenance) costs. Additional details of 

the data, methods, and assumptions underlying these costs are documented in the most recent 

information collection request (U.S. EPA, 2013).

Table 5-14 shows first and subsequent year average cost per facility subject to subpart W.

Table 5-14. Annual Average Cost Per Facility Subject to Subpart W

Subpart W 

Industry Segment

Total 

Number of 

Respondents

a

Total Cost

(2011$ per year)

Cost Per Facility

(2011$ per year)

First Year b Subsequent 

Years a First Year b Subsequent Years a

NG Processing 289 8,952,000 2,324,000 31,000 8,000

NG Transmission 1,145 17,249,000 7,303,000 15,100 6,400

Underground NG 

Storage 133 2,695,000 1,122,000 20,300 8,400

LNG Storage 33 792,000 270,000 24,000 8,200

LNG 

Import/Export 4 89,000 39,200 22,300 9,800

NG Distribution 143 2,089,000 1,498,000 14,600 10,500

Onshore 

Production 981 17,932,000 7,958,000 18,300 8,100

Offshore 

Production 58 525,000 227,000 9,100 3,900

a This data was extracted from Exhibit 6.1 of the Supporting Statement Part A: Information Collection Request For 

The Greenhouse Gas Reporting Program (U.S. EPA, 2013).

b The first year total cost are from the current cost & burden table identified as “First-Year Burden & Cost” in 

Appendix I-3 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas 

Reporting Program (U.S. EPA, 2013) and includes $80.91 from the current burden & cost table identified as “First 

Reporting Year” table of Appendix L-2 of the Supporting Statement Part A: Information Collection Request For 

The Greenhouse Gas Reporting Program (U.S. EPA, 2013). The $80.91 is the cost contributed to provisions of 

information on parent companies, NAICS codes, and whether emissions are from cogeneration. These costs were 

updated to 2011 dollars using the Bureau of Labor Statistics Employment Cost Index and the Chemical 

Engineering Plant Cost Index (CEPCI).

By revising the GWP values in subpart A, 99 additional facilities (refer to Table 5-12 to 

see these facilities by subpart W industry segment) will be required to report under subpart W. 
28

The first year cost for these facilities will be approximately $1,648,000 per year [(2 x 

$31,000)+(7 x $15,100)+(6 x $20,300)+(2 x $24,000)+(0 x $22,300)+(16 x $14,600)+(52 x 

$18,300)+(14 x $9,100) = $1,648,009], and the annualized industry wide cost is approximately

$772,000 per year [(2 x $8,000)+(7 x $6,400)+(6 x $8,400)+(2 x $8,200)+(0 x $9,800)+(16 x 

$10,500)+(52 x $8,1900)+(14 x $3,900) = $771,900].

5.3.4 Subpart W Small Entity Impacts (new reporters)

In the subpart W Economic Impact Analysis (U.S. EPA. 2010), EPA originally assessed 

the impact of complying with subpart W requirements on small entities in the petroleum and 

natural gas systems source category by calculating a cost-to-sales ratio for eight enterprise size 

ranges (i.e., all categories, 1 to 20 employees, 20 to 99 employees, 100 to 499 employees, 500 to 

749 employees, less than 500 employees, 750 to 999 employees, and 1,000 to 1,499 employees) 

using the ratio of average total annualized reporting costs to the average annual sales receipts for 

each establishment. The results of this analysis are represented in Table 9 of the preamble for the 

publication of the subpart W rule (75 FR 74482, November 30, 2010).

Based on this analysis, EPA concluded that subpart W will not have a significant 

economic impact on a substantial number of small entities. EPA made this determination 

assuming that all entities in the industry would report (including those above and below the 

reporting threshold) and determined that no significant small business economic impacts were 

expected to occur. This analysis showed that the cost–to-sales ratio for all entity sizes except for 

the smallest sized enterprises was less than 1 percent. EPA concluded that although the cost-tosales ratio for the 1 to 20 employee range for crude petroleum and natural gas extraction was 

greater than 1 percent (i.e., 1.33%); in most cases, the small enterprises in this size range have 

very small operations (such as single family owning a few production wells) that are highly 

unlikely to cross the 25,000 metric tons CO2e reporting threshold. It is unlikely that any of the 99 

new affected facilities that were estimated to become subject to subpart W (due to the revised 

GWP) would fall into the 1 to 20 employee range enterprise.

Therefore, the changes to the GWP will not have significant impact on a substantial 

number of small entities in Subpart W.

5.3.5 Subpart W (summary of impacts)

Table 5-15 summarizes the impacts of updating the GWP values in Table A-1 to subpart 

A, on new facilities required to report subpart W emissions.

Table 5-15. New Reporters—Summary of Subpart W Impacts Due to the Revisions to GWPs

Subpart W Industry 

Segment

Number of New 

Reporters Due 

to GWP 

Incremental 

CO2e Emissions 

for New 

Incremental Cost Impact For New 

Reporters

(2011$ per year)
29

Revisions Reporters

(metric tons of 

CO2e per year )

First Year a Subsequent 

Years a

NG Processing 2 52,067 62,000 16,100

NG Transmission 7 177,091 105,000 44,600

Underground NG Storage 6 158,286 122,000 50,600

LNG Storage 2 50,000 48,000 16,400

LNG Import/Export 0 0 0 0

NG Distribution 16 400,000 234,000 168,000

Onshore Production 52 1,372,641 951,000 422,000

Offshore Production 14 362,796 127,000 54,700

Total 99 2,572,881 1,648,000 772,000

a Values for total are rounded.

5.3.6 References for Subpart W

U.S. EPA, 2010. “Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions 

Under Subpart W Final Rule (GHG Reporting)”. Available at: 

http://www.epa.gov/ghgreporting/documents/pdf/2010/Subpart-W_EIA.pdf. 

U.S. EPA, 2013. Supporting Statement Part A: Information Collection Request For The Greenhouse Gas 

Reporting Program. OMB Control No. 2060-0629. EPA ICR No. 2300.10. May 2013.

5.4 Subpart HH 

Subpart HH applies to Municipal Solid Waste (MSW) landfills that accepted waste on or 

after January 1, 1980 and generate CH4 in amounts equivalent to 25,000 metric tons of CO2e per 

year or more.

5.4.1 Subpart HH (identifying new reporters)

According to the technical supporting document (TSD) for the Landfill Sector (U.S. 

EPA, 2009a), 2,551 MSW landfills were estimated to be subject to subpart HH. This includes 

771 active large MSW landfills, 230 active small landfills, and 1,550 closed landfills. The 

methods and database that were used to estimate the affected facilities for subpart HH in the TSD 

for the landfill sector (U.S. EPA, 2009a) can be divided into the following four categories:

Active Large MSW Landfills (771):

 The number of active large MSW landfills subject to subpart HH was identified based on 

the actual CH4 generation information for each active landfill in the Landfill Methane 

Outreach Program (LMOP) database in 2006. The CH4 generation rate in 2006 was 

calculated using the actual waste-in-place information and a landfill-specific model. The 

landfill-specific model used the first order decay model with a methane generation 

potential (L0) of 100 m3/mt and three different methane generation rate constant (k)

values based on rainfall levels (U.S. EPA, 2005a).
30

Active Small Landfills (230):

 It was estimated that there were 460 small active landfills in 2009 that were not covered 

by the 2006 LMOP database and 50% of them have CH4 generation greater than 25,000 

metric tons/yr of CO2e. Fifty percent was based on engineering judgments.

Closed Landfills (1,550):

 It was estimated that there were 6,200 closed landfills in 2009 and 25% of them have 

CH4 generation greater than 25,000 metric tons/yr of CO2e. Twenty-five percent was 

based on engineering judgments. 

Landfills that will Incur Additional Reporting Requirements in the Next Ten Years:

 Additional subsets of both active and closed landfills will incur additional GHG reporting 

burden over the ten-year period following the finalization of the CH4 GWP revision 

(assumed to occur in calendar year 2014). 

o Closed Landfills - It is estimated that 196 closed landfills have a current CH4

generation greater than 25,000 metric tons/yr CO2e and may be required to stay in 

the program longer with the revised CH4 GWP. This estimate was based on eGGRT data for the reporting year of 2011. 

o Active Landfills expected to close within 10 years - A similar issue will occur for 

landfills that are currently in operation but plan to close within the ten-year 

timeframe (calendar years 2015 through 2024). Based on data from the LMOP 

database (U.S. EPA, 2013a), it is estimated that 233 landfills will close during 

that ten-year timeframe that may incur an incremental reporting burden. 

 Of these 233 landfills, 230 either currently have CH4 generation greater 

than 25,000 metric tons/yr CO2e, or will have this generation rate in the 

scheduled closure year. 

 The remaining 3 landfills currently do not emit above 25,000 metric 

tons/yr CO2e and also would not in the scheduled closure year; however 

the revised CH4 GWP would result in the landfills emitting more than 

25,000 metric tons/yr CO2e at some point within the ten-year timeframe.

Based on the e-GGRT data for the reporting year of 2010, there are 1,202 MSW landfills 

that reported under subpart HH, including 936 active landfills and 266 closed landfills. The 

number of the closed MSW landfills reported under subpart HH (266) is significantly lower than 

the original estimate of 1,550 in the TSD for the landfill sector (U.S. EPA, 2009a). However, the 

number of active landfills reported (936) is close to the original estimate of 1,001 (771 active 

large + 230 active small) landfills. Therefore, except for closed landfills, the original methods 

used in the TSD for the landfill sector (U.S. EPA, 2009a) to estimate the number of affected 
31

active landfills is reasonable, and the same approach is used in this analysis to estimate the 

number of additional MSW landfills subject to subpart HH due to the revised CH4 GWP.

Because the reporting threshold for subpart HH is based on CH4 generation (not 

emissions), the facilities that currently have CH4 generation between 21,000 and 25,000 metric 

tons/yr of CO2e are the additional facilities affected by the GWP change for CH4 from 21 to 25. 

Because the CH4 generation from landfills changes with time and the amount of waste in place, 

the time factor should be considered in this analysis. The additional active large MSW landfills, 

active small MSW landfills, closed landfills, and landfills that will close within the next ten years 

subject to subpart HH are estimated as follows:

Additional Active Large MSW Landfills: 

Although the LMOP database (U.S. EPA, 2012) includes most of the input data (such as 

landfill open and closure years, amount of waste accepted, etc.) for the landfill-specific model 

used in the original analysis, this model was not re-run for this analysis. Therefore, the actual 

CH4 generation in 2011 for each MSW landfill covered by the LMOP database was not 

calculated. The best CH4 generation information available is the 2006 CH4 generation 

information in the supporting data for the TSD for the landfill sector (U.S. EPA, 2009a). 

According to this supporting data, there were 1,142 active large MSW landfills and 21 of them 

have CH4 generation between 21,000 and 25,000 metric tons/yr of CO2e based on 2006 LMOP 

database. This is equivalent to 1.8% of the total active landfills identified in LMOP database. 

According to the 2012 LMOP data (U.S. EPA, 2012), there are 1,123 active MSW landfills in 

2012 (excluding the closed landfills). Assuming that the profile of landfills not in the LMOP 

database is similar to those landfills in the LMOP database, the number of active large landfills 

with CH4 generation between 21,000 and 25,000 metric tons/yr of CO2e is estimated to be 1,123 

x 1.8% = 20 facilities. 

Additional Active Small MSW Landfills:

Small landfills are not included in the LMOP database, therefore a different approach was 

used to estimate the additional active small landfills affected by the change in GWP. In the TSD 

for the landfill sector (U.S. EPA, 2009a), it was estimated that there were 460 small active 

landfills in 2009 and 50% of them have CH4 generation greater than 25,000 metric tons/yr of 

CO2e and were included in the original estimates of number of reporting facilities. Thirty percent

of small landfills are estimated to have CH4 generation between 10,000 and 25,000 metric 

tons/yr of CO2e. Assuming that the proportion of all small active landfills is the same as those in 

the LMOP database, and the distribution across the available range of estimated emissions 

(10,000 to 25,000) is even, the number of small active landfills with CH4 generation between 
32

21,000 and 25,000 metric tons/yr of CO2e is estimated to be 460 x 30% x (25,000 – 21,000) / 

(25,000 – 10,000) = 37 facilities.

Additional Closed MSW Landfills:

For closed landfills, CH4 generation and emissions decrease over time. It is estimated that 

the CH4 generation decreases 18% in 5 years based on the CH4 generation calculated using 

EPA’s Landfill Gas Emissions Model (LandGEM) (U.S. EPA, 2005b). The closed MSW 

landfills identified in the 2006 LMOP database with CH4 generation equal to 25,000 metric tons 

of CO2e now should have CH4 generation around 25,000 x (1-18%) = 20,500 metric tons/yr of 

CO2e in 2011. With the updated GWP for CH4, the CH4 generation for these landfills is 20,500 / 

21 x 25 = 24,405 metric tons/yr of CO2e, which is still less than the reporting threshold of 25,000 

metric tons/yr. Therefore, the closed landfills that were identified in 2006 and with CH4

generations between 21,000 and 25,000 metric tons/yr of CO2e still would not exceed the 25,000 

metric tons/year generation threshold of subpart HH after 2011 due to the revised CH4 GWP. 

According to the 2012 LMOP data, 92 MSW landfills were closed in the time period of 2007 

through 2011 (U.S. EPA, 2012). Based on the waste in place information, none of these newly 

closed landfills have CH4 generation between 21,000 tons and 25,000 tons of CO2e based on a 

GWP for CH4 of 21. Therefore, no additional closed landfills are expected to exceed the 25,000 

metric tons/year generation threshold using a GWP of 25.

Additionally, as part of the final rule requirements, EPA has revised the applicability

provisions for subpart HH to exclude closed landfills that have not previously had to report under 

subpart HH that would be required to newly report in 2014 by exceeding the 25,000 metric tons 

CO2e emissions threshold for the first time solely due to the increase in the GWP of CH4.

Specifically, EPA is revising 40 CFR 98.340 to add a paragraph to state: “This source category

does not include MSW landfills that have not received waste on or after January 1, 2013, and 

that had CH4 generation, as determined using both Equation HH-5 and Equation HH-7 of this 

subpart, of less than 1,190 metric tons of CH4 in the 2010, 2011, 2012 and 2013 reporting years.” 

Therefore, no additional closed landfills meeting these provisions would be required to newly

report under subpart HH in 2014. 

Landfills that will Incur Additional Reporting Requirements in the Next Ten Years:

Although landfill closure dates and waste-in-place information are available in the LMOP 

database (U.S. EPA, 2013a), e-GGRT data for the 2012 reporting year was used to identify 43 

closed landfills that would incur additional reporting requirements. 

For the 196 closed landfills with CH4 generation greater than 25,000 metric tons/yr CO2e, 

a total of 36 (18%) were identified as facilities that over the next ten years, will required to report 

for more years than originally anticipated. An analysis was conducted for reporters that may
33

have additional years of reporting over the next ten years. Using the modeled generation rates for 

closed landfills in the subpart HH rule, a typical rate of decline in CH4 generation was calculated 

for closed landfills equivalent to a 3.6% reduction in CH4 generation each year and assumed that 

is a linear reduction (18% over five years). This value matched well with the modeled decrease 

in CH4 generation in the LMOP database. The annual CH4 generation reported in e-GGRT was 

reduced by this amount for a period of ten years, with each year being analyzed in sequence. 

There were a total of 36 landfills that were predicted to be subject to at least one year of 

additional GHG required reporting with an increase in the CH4 GWP from 21 to 25.

For active landfills that are planning to close within the next ten years, the LMOP 

database was selected as the source of information to use in the economic impact analysis instead 

of the e-GGRT 2012 reporting year data. This is because a subset of the applicable active 

landfills may not be currently subject to subpart HH and thus not currently required to report 

GHG emissions through e-GGRT. A total of four active landfills that are planned to close within 

the next ten years were identified as facilities that may be required to report for more years than 

originally anticipated over the ten year period. The LMOP database provides an annual waste 

acceptance rate which was used to estimate the total waste-in-place in the planned closure year. 

This waste amount was used to calculate CH4 generation in the closure year using Equation HH1 from subpart HH. CH4 generation was then scaled downwards by 3.6% each year, with each 

year being analyzed in sequence.

The active landfills in the LMOP database were also researched for instances where the 

CH4 GWP of 21 would never result in the landfill emitting greater than 25,000 metric tons CO2e, 

but would be above this threshold within the next ten years using a CH4 GWP of 25. These 

represent landfills that would trigger the reporting requirements of subpart HH. These landfills 

would not be covered under the large or small active landfill sections described above because 

the increased CH4 GWP would not result in subpart HH applicability in the current year; instead, 

the landfill would trigger the reporting requirements of subpart HH at some point within the next 

ten years. An identical year-over-year analysis was conducted for the three landfills identified.

Based on the discussions above, Table 5-16 identifies the number of new subpart HH 

reporters that will become subject to the rule as a result of revisions to the GWPs in Table A-1.

Table 5-16. New Subpart HH Reporters by Type of MSW Landfill

Type of MSW Landfill Number of New Reporters Due to GWP Revisions

Large Active Landfills 20

Small Active Landfills 37

Closed Landfills 0

Landfills that will Incur Additional Reporting 

Requirements in the Next Ten Years 43
34

Total 100

5.4.2 Subpart HH (estimating emissions impacts)

From Table 5-16, there would be 57 additional facilities subject to subpart HH due to the 

revised CH4 GWP. Emissions from these 57 additional facilities were estimated by multiplying 

the number of new affected facilities (57) by the average CH4 generation for each new affected 

facility. The average CH4 generation for each new affected facility is assumed to be (25,000 + 

21,000)/2 x 25/21 = 27,381 metric tons/yr of CO2e. The amount of CO2 equivalent has been 

adjusted using the new GWP for CH4 of 25. Therefore, the total CH4 generation for all new 

affected facilities combined is equal to about 1,560,000 metric tons/yr of CO2e (57 x 27,381 = 

1,560,717). Table 5-17 identifies the emissions impact from new subpart HH reporters.

Table 5-17. Emissions Impact From New Subpart HH Reporters

Facility Type Incremental CO2e Emissions for New Reporters

(metric tons of CO2e per year )

HH –

MSW Landfills 1,560,000

5.4.3 Subpart HH (estimating cost impacts)

Costs were calculated by multiplying the average costs per facility and the number of 

new facilities estimated to be subject to subpart HH (from revising the GWPs). Average costs per 

facility were calculated by dividing total cost by the number of respondents identified in the most 

recent information collection request for the GHG reporting program (U.S. EPA, 2013). 

Appendices G and L to the most recent information collection request for the GHG 

reporting program (U.S. EPA, 2013) were used to obtain first year average cost per facility that 

is incurred from reporting under subpart HH. Cost details from Exhibit 6.1 of the most recent 

information collection request for the GHG reporting program (U.S. EPA, 2013) were used to 

determine the subsequent years average cost per facility. These average costs per facility include 

labor costs (i.e., the cost of labor by facility staff to meet the rule’s information collection 

requirements) and non-labor (capital, and operation and maintenance) costs. Additional details of 

the data, methods, and assumptions underlying these costs are documented in the most recent 

information collection request (U.S. EPA, 2013).

Table 5-18 shows first and subsequent year average cost per facility subject to subpart 

HH.

Table 5-18. Annual Average Cost Per Facility Subject to Subpart HH

Subpart Total Number of 

Respondents a

Total Cost

(2011$ per year)

Cost Per Facility

(2011$ per year)
35

First Year b Subsequent 

Years a First Year b Subsequent Years a

HH –

MSW Landfills 1,195 10,894,000 2,804,000 4,300 2,300

a This data was extracted from Exhibit 6.1 of the Supporting Statement Part A: Information Collection Request For 

The Greenhouse Gas Reporting Program (U.S. EPA, 2013).

b This data was extracted from the current burden & cost table in Appendix G-3 of the Supporting Statement Part 

A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). The one-time 

costs in Appendix G-3 ($2,497,000 or $2,644,000 when updated to 2011 dollars) were added to the "HH. 

Landfills" cost provided in Appendix G-3 ($7,736,000 or $8,046,000 updated to 2011 dollars). The costs were 

updated to 2011 dollars using the Bureau of Labor Statistics Employment Cost Index and the Chemical 

Engineering Plant Cost Index (CEPCI). An additional $204,216 ($80.91 per respondent) was added to the total 

first year cost based on the current burden & cost table identified as “First Reporting Year” table of Appendix L-2 

of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program 

(U.S. EPA, 2013). The $80.91 is the cost contributed to provisions of information on parent companies, NAICS 

codes, and whether emissions are from cogeneration. These calculations (that were used to determine the first year 

total cost, and cost per facility) are based on an estimated 2,524 respondents to be consistent with Appendix G-3.

By revising the GWP values in subpart A, 57 additional facilities will be required to

report under subpart HH. The first year cost for these 57 facilities will be approximately

$246,000 per year (57 x $4,300 = $246,000), and the annualized industry wide cost is $133,700 

per year (57 x $2,346 = $133,700). An additional 43 closed or soon to-be-closed landfills will 

experience an incremental reporting burden over the next ten year period, due to an extended 

number of years reporting would be required; total additional rule implementation costs would 

be $373,600 for these landfills over that ten year period, or an average of $37,360 per year. This 

includes extended subsequent year reporting costs for 36 closed landfills, first year reporting 

costs for three active facilities that would be brought into Part 98 as a result of the revised 

GWPs, and extended subsequent year reporting costs for four active facilities that are expected to 

closed between 2014 and 2024, as summed over a ten-year period . A year-over-year breakdown 

of these costs is included in Section 5.4.5 below. 

5.4.4 Subpart HH Small Entity Impacts (new reporters)

The small entity economic impact for landfills was measured using the “sales tests” 

approach (represented as cost-to-receipt ratios) for NAICS codes associated with the affected 

subparts in the Regulatory Impact Analysis for the GHG Reporting Rule (U.S. EPA, 2009b). The 

same approach is used in this analysis for the additional facilities subject to subpart HH due to 

the revised CH4 GWP. If the ratio of rule implementation cost to sales is less than 1%, the impact 

is not considered to be significant (U.S. EPA, 2010b).

Based on the 2007 economic census database published by U.S. Bureau of the Census, 

the receipts (sales), number of establishments, and the average receipts for different size of 

Waste Management and Remediation Services facilities (with a NAICS code of 562) information 
36

is summarized in Table 5-19. The average receipts information is adjusted from 2007 dollars to 

2011 dollars based on the consumer price index published by Bureau of Labor Statistics. 

Table 5-19. Receipts, Number of Establishments, and Average Receipts for 

Waste Management and Remediation Services (NAICS code of 562)

Owned by Enterprises with:

1-19

Employees

20-99 

Employees

100-249 

Employees

250-499 

Employees

500-999 

Employees

1,000 and 

above 

Employees

Receipts

(million, 2007$) $10,492 $14,318 $6,856 $3,365 $3,732 $35,420

Number of 

Establishments 12,579 2,678 646 248 263 2,910

Average Receipts for 

Each Establishment

(million, 2007$)

$0.83 $5.35 $10.61 $13.57 $14.19 $12.17

Average Receipts for 

Each Establishment

(million, 2011$)

$0.90 $5.80 $11.51 $14.72 $15.40 $13.20

According to the cost information listed in Table 5-18, the rule implementation costs for 

subpart HH is $4,300 for the first year and $2,300 for the subsequent years (in 2011 dollars). The 

sales tests (cost-to-receipt ratios) results are shown in Table 5-20 for the first year and 

subsequent years.

Table 5-20. Sales Tests for Subpart HH Facilities

Owned by Enterprises with:

1-19

Employees

20-99 

Employees

100-249 

Employees

250-499 

Employees

500-999 

Employees

1,000 and 

above 

Employees

Sales Test –

First Year 0.48% 0.07% 0.04% 0.03% 0.03% 0.03%

Sales Test -

Subsequent Years 0.26% 0.04% 0.02% 0.02% 0.01% 0.02%

The results in Table 5-20 show that the costs for GHG reporting for the facilities subject 

to subpart HH is well below 1% of the sales for all size of Waste Management and Remediation 

Services facilities with a NAICS code of 562. Therefore, it was determined that there is not a 

significant impact on a substantial number of small businesses subject to reporting under subpart 

HH as a result of this action.

5.4.5 Subpart HH (summary of impacts)

Table 5-21 summarizes the impacts of updating the GWP values in Table A-1 to subpart 

A, on new facilities required to report subpart HH emissions. 
37

Table 5-21. New Reporters—Summary of Subpart HH Impacts Due to the Revisions to GWPs

Facility Type

Number of New 

Reporters Due 

to GWP 

Revisions

Incremental 

CO2e Emissions 

for New 

Reporters

(metric tons of 

CO2e per year ) a

Incremental Cost Impact For New 

Reporters

(2011$ per year)

First Year a Subsequent 

Years a

HH –

MSW Landfills 57 1,560,000 246,000 133,700

a Values rounded.

The incremental reporting burden is provided in year-over-year format in Table 5-22 for 

both the new reporters and the 43 existing facilities that would trigger extended reporting 

requirements over the following ten years. The costs for closed facilities were calculated based 

on applying first year and subsequent year costs to the facilities identified (see “Landfills that 

will Incur Additional Reporting Requirements in the Next Ten Years”, Section 5.4.1) in each 

year for which the facility would be subject to extended reporting requirements or would be 

brought into Part 98. This includes extended subsequent year reporting costs ($2,300 per facility) 

for 36 landfills that are or would be closed by 2014, first year reporting costs ($4,300 per 

facility) for three active facilities that would be brought into Part 98 as a result of the revised

GWPs, and extended subsequent year reporting costs ($2,300 per facility) for four active

facilities that are currently receiving waste but are expected to close between 2014 and 2024.

Table 5-22. Summary of Subpart HH Cost Impacts 

$/year 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Landfills 

Closed 

before 

2024

18,800 28,100 30,100 35,100 39,800 46,800 44,500 46,800 37,400 45,900

New 

Reporters 246,000 133,700 133,700 133,700 133,700 133,700 133,700 133,700 133,700 133,700

Totala264,800 161,800 163,800 168,800 173,500 180,500 178,200 180,500 171,100 179,600

a Total average Incremental Cost Impact for New Reporters and Reporters with Extended Reporting Requirements is 

$182,200 per year.

5.4.6 References for Subpart HH

U.S. EPA, 2005a. Development of Landfill-specific Methane Inventory Model; Memorandum from Jeff 

Coburn and Marvin Branscome, RTI, to Elizabeth Scheele, EPA. See Docket ID: EPA-HQ-OAR-2008-

0058-0083.May 6, 2005.

U.S. EPA, 2005b. Landfill Gas Emissions Model (LandGEM), , Version 3.02. [Computer software]. 

Retrieved July 12, 2012. Available from http://www.epa.gov/ttn/catc/products.html#software

U.S. EPA, 2009a. Technical Support Document for the Landfill Sector: Proposed Rule for Mandatory 

Reporting Of Greenhouse Gases. See Docket ID: EPA-HQ-OAR-2008-0508-0034. February 4, 2009.
38

U.S. EPA, 2009b. Regulatory Impact Analysis for the Mandatory Reporting of Greenhouse Gas 

Emissions Final Rule (GHG Reporting). See Docket ID: EPA-HQ-OAR-2008-0508-2229. September 

2009.

U.S. EPA, 2012. Landfill Methane Outreach Program (LMOP) – Landfill and Project Database. January 

4, 2012. Available from: http://www.epa.gov/lmop/documents/xls/lmopdata.xls

U.S. EPA, 2013a. Landfill Methane Outreach Program (LMOP) – Landfill and Project Database. June 13, 

2013. Available from: http://www.epa.gov/lmop/documents/xls/lmopdata.xls

U.S. EPA, 2013b. Supporting Statement Part A: Information Collection Request For The Greenhouse 

Gas Reporting Program. OMB Control No. 2060-0629. EPA ICR No. 2300.10. May 2013.

5.5 Subpart II 

The industrial wastewater treatment source category consists of anaerobic processes used 

to treat industrial wastewater and industrial wastewater treatment sludge at facilities that perform 

the following operations: petroleum refining; pulp and paper manufacturing facilities; ethanol 

production; and food processing.

Facilities that meet reporting thresholds must report the amount of CH4 generated, 

emitted, and/or recovered from anaerobic treatment of industrial wastewaters and industrial 

wastewater treatment sludges. Subpart II applies only to anaerobic treatment processes. 

For the industries covered by subpart II, the reporting thresholds are specified as follows:

 Petroleum refineries are required to report if the facility is subject to reporting 

under subpart Y of 40 CFR part 98. There is no threshold for reporting. 

 Pulp and paper manufacturing facilities are required to report if the facility emits

25,000 metric tons CO2e or more per year. All pulp and paper facilities are 

expected to meet this threshold. 

 Ethanol production facilities are required to report if the facility emits 25,000 

metric tons CO2e or more per year.

 Food processing facilities are required to report if the facility emits 25,000 metric 

tons CO2e or more per year.

5.5.1 Subpart II (identifying new reporters)

This section discusses how EPA estimated the number of facilities required to report 

during the development of the Greenhouse Gas Reporting Rule. It then discusses how these 

estimates would change if the methane GWP increased from 21 to 25. The discussion is 

presented separately for each of the four industries included in subpart II.

Petroleum refineries. During the development of the GHG reporting rule, EPA noted that 

40 CFR 98.2(a)(1) requires all 150 petroleum refineries to report their GHG emissions. As part 

of the estimate of the potential costs of subpart II, EPA further estimated that 25% of refineries 

have anaerobic wastewater treatment and would be required to report subpart II emissions (ERG, 
39

2010). However, in the 2011 reporting year, there were no facilities identified that reported both 

petroleum refining emissions and subpart II emissions. For these reasons, any change to the 

methane GWP will have no impact on the estimated number of petroleum refineries required to 

report subpart II emissions. 

Pulp and paper manufacturing facilities. During the development of the GHG reporting 

rule, as part of the estimate of the potential costs of subpart II, EPA estimated that 25% of the 

565 U.S. pulp and paper mills have anaerobic treatment. EPA further assumed that all 141 mills 

with anaerobic secondary treatment would meet the 25,000 metric tons CO2e threshold of 

emissions from their subpart AA operations and would be required to report subpart II emissions 

(ERG, 2010). In the 2011 reporting year, there were 7 facilities that reported both pulp and paper 

manufacturing emissions and subpart II emissions. Because mills are assumed to meet the 

reporting threshold based on their subpart AA CO2 emissions, any change to the methane GWP 

will have no impact on the estimated number of pulp and paper mills required to report subpart II 

emissions. 

Ethanol production facilities. Ethanol production facilities are required to report their 

GHG emissions if they exceed 25,000 metric tons CO2e per year in combined emissions from all 

specified sources, such as stationary fuel combustion units, industrial landfills, and industrial 

wastewater treatment. However, for the purpose of its March 2010 cost estimate, because EPA 

had no basis for estimating emissions from other sources at the ethanol production facility, EPA 

assumed facilities that exceed 25,000 metric tons CO2e per year in emissions from industrial 

wastewater treatment would incur monitoring costs (ERG, 2010).

Facilities use one of two processes to produce ethanol: dry milling or wet milling. During 

the development of the GHG reporting rule, EPA obtained information from the Renewable 

Fuels Association that included facility identification, production, and whether the facility used 

dry milling or wet milling. This information did not identify facilities that use anaerobic 

wastewater treatment. Assuming each facility used anaerobic treatment and using standard waste 

generation rates based on ethanol production, chemical oxygen demand (COD) concentrations, 

and methane generation rates, EPA calculated potential methane emissions per plant. 

Dry milling. The maximum estimated emissions from a facility were slightly over 1,800 

metric tons CO2 e per year. Even if the methane GWP were increased by 20%, no dry milling 

ethanol plant would meet the 25,000 metric tons CO2 e per year reporting threshold.

Wet milling. Wet milling ethanol production facilities generate more wastewater per unit 

of production and have somewhat greater production per facility than dry milling facilities. Four 

wet milling facilities produce 1.5 to 2.5 times as much ethanol as the largest dry milling facility. 

Because EPA had very little information on how individual ethanol production facilities treat 
40

wastewater, in order to estimate the potential costs of subpart II, EPA estimated that 33% of the 

wet milling facilities used anaerobic wastewater treatment. Using standard waste generation rates 

based on ethanol production, COD concentrations, and methane generation rates, EPA calculated 

that four (4) wet milling facilities emitted in excess of the 25,000 metric tons CO2 e per year 

reporting threshold. EPA estimated that ethanol production facilities would incur $20,600 in total 

annualized costs to meet the GHG reporting rule monitoring requirements (ERG, 2010), or 

$5,150 per facility.

In a more recent analysis, EPA estimated that two wet milling ethanol production 

facilities exceeded the reporting threshold. Changing the GWP to 25 would increase this estimate 

by two, to a total of four facilities. In the 2011 reporting year, there were 17 ethanol production 

facilities that reported subpart II emissions. However, the subpart II emissions for each of these 

facilities were under the 25,000 tons per year threshold; the facilities exceeded the threshold 

based on subpart C combustion emissions. Using these sources of information, it is estimated 

that the impact of a change to the GWP for methane from 21 to 25 will result in two additional 

facilities that will be required to report.

Food processing facilities. Food processing facilities are required to report their 

wastewater emissions if Facility GHG emissions exceed 25,000 metric tons CO2e per year in 

combined emissions from all specified sources, such as stationary fuel combustion units, 

industrial landfills, and industrial wastewater treatment. However, for the original development 

of the rule, because EPA had no basis for estimating emissions from other sources at the food 

processing facility, EPA assumed facilities that exceed 25,000 metric tons CO2e per year in 

emissions from anaerobic industrial wastewater treatment alone would be subject to the rule 

(ERG, 2010). Food processing facilities that are most likely to have anaerobic wastewater 

treatment are: 1) fruits and vegetable processing, 2) poultry processing, and 3) red meat 

processing. 

Fruits and vegetable processing. During the development of the GHG reporting rule, as 

part of the estimate of the potential costs of subpart II, EPA estimated that no fruit and vegetable 

processing facilities would incur reporting costs because all would be under the reporting 

threshold (ERG, 2010). As discussed in the July 2008 threshold analysis (ERG, 2008b), EPA 

could not identify plant-specific information to calculate greenhouse gas emissions for fruit and 

vegetable processors. The national level of emissions from the 2006 U.S. Inventory of U.S. 

Greenhouse Gas Emissions and Sinks is 123,000 metric tons CO2e. There are approximately 100 

processors with onsite anaerobic treatment (U.S. EPA, 2008); therefore, the average emission 

was estimated to be about 1,200 metric tons CO2e per plant (ERG, 2008b). If the methane GWP 

increased from 21 to 25, the average emission would increase to about 1,460 metric tons CO2e 

per plant, still significantly below the 25,000 metric tons CO2e reporting threshold. Thus, an 
41

increase in the methane GWP would have no effect on the number of fruit and vegetable 

processing facilities required to report subpart II emissions.

Poultry processing. During the development of the GHG reporting rule, as part of the 

estimate of the potential costs of subpart II, EPA determined it did not have sufficient 

information to estimate the number of poultry processing facilities that exceed the 25,000 metric 

ton CO2e reporting threshold. EPA estimated 50 poultry processors have methane emissions 

above 10,000 metric tons CO2e (ERG, 2010). This is an overestimate of those that have 

emissions above 25,000 metric tons CO2e, but EPA does not have sufficient facility-specific 

information to refine the estimate, nor to estimate the impact of changing the methane GWP.

As described in the July 17, 2008 memorandum (ERG, 2008b), EPA was unable to obtain 

plant-specific information for poultry processors; neither production levels nor whether facilities 

use anaerobic wastewater treatment were found. Therefore, using national default values for 

wastewater generation, COD in wastewater concentrations, and assuming all wastewater is 

treated anaerobically on site, EPA back-calculated the production rate that would trigger each of 

four emission thresholds. EPA estimated that production of 93 million lb/yr would result in 

emissions exceeding 10,000 metric tons CO2e. Production of 232 million lb/yr would result in 

emissions exceeding 25,000 metric tons CO2e. EPA had publicly available data obtained to 

support EPA Office of Water’s effluent guidelines for the meat and poultry products industry. 

These data classified “nonsmall” poultry processors as facilities producing more than 100 million 

pounds per year and reported 206 “nonsmall” poultry producers. The data also indicated that 

25% of the industry uses onsite anaerobic treatment. Consequently, EPA estimated that 50 

poultry producers (206 x 25%) would exceed the 10,000 metric tons CO2e threshold (ERG, 

2008b). EPA used this estimate as a conservatively high estimate of the number of poultry

producers that would be subject to subpart II. Because this estimate includes producers with 

emissions as low as 10,000 metric tons CO2e, no additional facilities are estimated to report as a 

result of the change in GWP of methane from 21 to 25. 

Red meat processing. During the development of the GHG reporting rule, as part of the 

estimate of the potential costs of subpart II, EPA estimated 13 red meat processors have methane 

emissions above 25,000 metric tons CO2e. As described in July 17, 2008 memorandum (ERG, 

2008b), EPA was unable to obtain plant-specific information for red meat processors, neither 

production levels nor whether facilities use anaerobic wastewater treatment. EPA used limited 

published information and engineering judgment to estimate the number of red meat processing 

facilities required to report, as follows: 
42

 Data available on Tyson Foods5indicates that covers have been installed on 

anaerobic lagoons at five meat processing plants (4 beef, 1 pork). Prior to the 

installation of the covers, all five sites were estimated to emit more than 25,000 

metric tons CO2e and one of these sites emitted more than 100,000 metric tons 

CO2e. Following installation of the covers, only one of these sites emits more than 

25,000 metric tons CO2e and three more emit more than 10,000 metric tons CO2e.

 Data from Cargill Meat Solutions, Inc. (Cargill)6indicate they have installed 

covers on all of their anaerobic lagoons at U.S. meat packing plants (8 beef, 2 

pork). It is estimated that these plants would have emitted more than 25,000 

metric tons CO2e each. It is unknown what their actual emissions are now.

From these data, it is estimated that no more than 13 meat processing facilities actually

emit more than 25,000 metric tons CO2e (ERG, 2008b). Because so few red meat processing 

facilities are required to report using the current GWP, it is likely that no new facilities will be 

required to report if the GWP for methane increases from 21 to 25. 

Table 5-23 identifies the number of new subpart II reporters that will become subject to 

the rule as a result of revisions to the GWPs in Table A-1.

Table 5-23. New Subpart II Reporters

Facility Type Number of New Reporters Due to 

GWP Revisions

Petroleum 0

Pulp and Paper 0

Ethanol 2

All Others 0

Total 2

5.5.2 Subpart II (estimating emissions impacts)

Because there are no new petroleum refiners, pulp and paper manufacturing facilities, and 

food processing facilities anticipated to be affected by the revised GWPs, there is no emissions 

impact from new subpart II reporters related to these facility types. However, it is estimated that 

emissions will increase by 59,500 metric tons CO2e per year from the two additional facilities 

that are expected to report. This estimate is based on the threshold analysis discussed in section 

5.5.1 which was used to determine the increase in emissions from the additional reporters that 

would be expected due to the revised GWPs in Table A-1. Table 5-24 identifies the emissions 

impact from new subpart II reporters.

 

5 Verification of Blue Source Emissions Reductions Credits from Methane Capture and Flare Projects at Tyson 

Foods Facilities, prepared by RAVEN RIDGE RESOURCES, INCORPORATED, February 23, 2004.

6

Cargill’s Corporate Citizenship Review.
43

Table 5-24. Emissions Impact From New Subpart II Reporters

Facility Type Incremental CO2e Emissions for New Reporters

(metric tons of CO2e per year )

Petroleum 0

Pulp and Paper 0

Ethanol 59,500

All Others 0

Total 59,500

5.5.3 Subpart II (estimating cost impacts)

Costs were calculated by multiplying the average costs per facility and the number of 

new facilities estimated to be subject to subpart II (from revising the GWPs). Average cost per 

facility for the first year was calculated by dividing total cost by the number of respondents 

identified in the initial information collection request for subpart II (U.S. EPA, 2010). Average 

cost per facility for subsequent years was calculated by dividing total cost by the number of 

respondents identified in the most recent information collection request for the GHG reporting 

program (U.S. EPA, 2013). 

Appendix A to the initial information collection request for subpart II (U.S. EPA, 2010) 

and Appendix L-2 of the most recent information collection request for the GHG reporting 

program (U.S. EPA, 2013) were used to obtain first year average cost per facility that is incurred 

from reporting under subpart II. Cost details from Appendices H-1 and L-2 of the most recent 

information collection request for the GHG reporting program (U.S. EPA, 2013) were used to 

determine the subsequent years average cost per facility. These average costs per facility include 

labor costs (i.e., the cost of labor by facility staff to meet the rule’s information collection 

requirements) and non-labor (capital, and operation and maintenance) costs. Additional details of 

the data, methods, and assumptions underlying these costs are documented in the information 

collection requests (U.S. EPA, 2010 and U.S. EPA, 2013).

Table 5-25 shows first and subsequent year average cost per facility subject to subpart II.

Table 5-25. Annual Average Cost Per Facility Subject to Subpart II

Subpart

Total Number 

of 

Respondents a

Total Cost

(2011$ per year)

Cost Per Facility

(2011$ per year)

First Year b Subsequent 

Years a First Year b Subsequent Years a

Petroleum 150 625,000 605,900 4,200 4,040

Pulp and Paper 141 627,000 607,900 4,400 4,300

Ethanol 4 21,600 21,000 5,400 5,300

All Others 63 263,000 254,500 4,200 4,040

a The total number of respondents and the subsequent year costs are from Appendix H-1 of the Supporting Statement 
44

Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). The 

subsequent costs include $44.25 from the revised burden & cost table identified as “Average Annual Burden and 

Cost” table of Appendix L-2 of the Supporting Statement Part A: Information Collection Request For The 

Greenhouse Gas Reporting Program (U.S. EPA, 2013). The $44.25 is the cost contributed to provisions of 

information on parent companies, NAICS codes, and whether emissions are from cogeneration.

b The first year costs are from the “Year 1” table of Appendix A to the initial information collection request for 

subpart II (U.S. EPA, 2010). The first year cost includes $80.91 from the current burden & cost table identified as 

“First Reporting Year” table of Appendix L-2 of the Supporting Statement Part A: Information Collection Request 

For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). The $80.91 is the cost contributed to provisions of 

information on parent companies, NAICS codes, and whether emissions are from cogeneration. These costs were 

updated to 2011 dollars using the Bureau of Labor Statistics Employment Cost Index and the Chemical Engineering 

Plant Cost Index (CEPCI).

By revising the GWP values in subpart A, two additional ethanol production facilities 

will be required to report under subpart II. The first year cost for these facilities will be 

approximately $10,800 per year (2 x $5,400 = $10,800), and the annualized industry wide cost is

$10,500 per year (2 x $5,270 = $10,500).

5.5.4 Subpart II Small Entity Impacts (new reporters)

The only additional subpart II reporters expected as a result of a change to the GWP of 

methane from 21 to 25 are two ethanol production facilities. Both of these facilities are owned by 

a large corporation that has been determined not to be a small entity. Therefore, it was

determined that there are no small entity impacts to any subpart II reporters associated with this 

action.

5.5.5 Subpart II (summary of impacts)

Table 5-26 summarizes the impacts of updating the GWP values in Table A-1 to subpart 

A, on new facilities required to report subpart II emissions.

Table 5-26. New Reporters—Summary of Subpart II Impacts Due to the Revisions to GWPs

Facility Type

Number of New 

Reporters Due 

to GWP 

Revisions

Incremental 

CO2e Emissions 

for New 

Reporters

(metric tons of 

CO2e per year ) a

Incremental Cost Impact For New 

Reporters

(2011$ per year)

First Year a Subsequent 

Years a

Petroleum 0 - - -

Pulp and Paper 0 - - -

Ethanol 2 59,500 10,800 10,500

All Others 0 - - -

Total 2 59,500 10,800 10,500

a Values rounded.
45

5.5.6 References for Subpart II

ERG, 2008b. Memorandum: Revised Threshold Analysis for the Estimation of Greenhouse Gas 

Emissions from Individual Industrial Facilities. Prepared for Melissa Weitz, EPA. See Docket ID: EPAHQ-OAR-2008-0508-0132. See Docket ID: EPA-HQ-OAR-2008-0508-0132. July 17, 2008.

ERG, 2010. Memorandum: Greenhouse Gas Reporting Rule, Industrial Wastewater Treatment Source 

Category, Costs for Final Rule Monitoring Requirements – Revised. Prepared for Rachel Schmeltz, EPA. 

See Docket ID: EPA-HQ-OAR-2008-0508-2297. March 5, 2010.

U.S. EPA, 2008. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006. April 2008. 

USEPA #430-R-08-005.

U.S. EPA, 2010. Supporting Statement Part A: Information Collection Request for the Mandatory 

Reporting of Greenhouse Gases from Magnesium Production, Underground Coal Mines, Industrial 

Wastewater Treatment, and Industrial Waste Landfills – Final Rule. OMB Control No. 2060-0647. EPA 

ICR No. 2396.01. July 2010.

U.S. EPA, 2013. Supporting Statement Part A: Information Collection Request For The Greenhouse Gas 

Reporting Program. OMB Control No. 2060-0629. EPA ICR No. 2300.10. May 2013.

5.6 Subpart OO 

Subpart OO applies to the suppliers of industrial GHGs source category, which consists 

of all facilities that produce a fluorinated GHG or nitrous oxide, and any importer or exporter of 

fluorinated GHGs or nitrous oxide with annual bulk imports or exports that are equivalent to 

25,000 metric tons CO2e or more. F-GHGs that do not appear on Table A-1 are not included in 

the threshold analysis. However, if a supplier of industrial GHGs is above the threshold of 

25,000 metric tons CO2e based on the Table A-1 chemicals, they must report production, 

imports and exports of all F-GHG.

5.6.1 Subpart OO (identifying new reporters)

All production facilities are required to report regardless of threshold, therefore, there are 

not additional facilities as a result of the revised GWPs. 

A list of importers and exporters was developed for the 2009 subpart OO threshold 

analysis (U.S. EPA, 2009) and for the addition of bulk exporters to the threshold analysis 

(Ottinger, 2009). As described in the referenced reports, this list was developed using 

information obtained primarily from the Port Import Export Reporting Service (PIERS), a 

database that collects, organizes and stores bills of lading from port cargo. These data were 

supplemented with data obtained from industry representatives through the Alliance for 

Responsible Atmospheric Policy. 

Table 5-27 shows the number of facilities that EPA identified for each of the industry

segments covered by subpart OO that would report. 
46

Table 5-27. Number of Facilities Reporting by Industry Segment

Segment Number of Facilities

Number of Facilities Expected to 

Report

HFC, PFC, SF6 and NF3 Producers 12 12

N2O Producers 5 5

N2O and Fluorinated GHG Importers 116 61

N2O and Fluorinated Exporters 192-244a89a

a The number of facilities was estimated as an upper bound and lower bound estimate. The data contained many 

similar, but not identically named companies. 

This list of importers and exporters was used to determine the additional facilities that 

would be required to report under subpart OO if the revised GWPs from the IPCC Fourth 

Assessment Report were used. The import and export quantities for each importer and exporter 

were multiplied by the revised GWPs to determine which entities would exceed the threshold of 

25,000 metric tons CO2e, and be required to report using the revised GWP. It is estimated that 

approximately three additional importer or exporter entities would be required to report as a 

result of the revisions to the GWPs for compounds currently in Table A-1. Table 5-28 identifies 

the emissions impact from new subpart OO reporters.

Table 5-28. New Subpart OO Reporters

Facility Type Number of New Reporters Due to 

GWP Revisions

OO –

Industrial GHG Suppliers 3

5.6.2 Subpart OO (estimating emissions impacts)

Each new reporter was estimated to report at the threshold of 25,000 metric tons CO2e 

because ERG assumed these facilities would only just meet the 25,000 metric tons CO2e 

reporting threshold. Table 5-29 identifies the emissions impact from new subpart OO reporters.

Table 5-29. Emissions Impact From New Subpart OO Reporters

Facility Type Incremental CO2e Emissions for New Reporters

(metric tons of CO2e per year )

OO –

Industrial GHG Suppliers 75,000

5.6.3 Subpart OO (estimating cost impacts)

Costs were calculated by multiplying the average costs per facility and the number of 

new facilities estimated to be subject to subpart OO (from revising the GWPs). Average costs per 

facility were calculated by dividing total cost by the number of respondents identified in the most 

recent information collection request for the GHG reporting program (U.S. EPA, 2013). 
47

Appendices G and L to the most recent information collection request for the GHG 

reporting program (U.S. EPA, 2013) were used to obtain first year average cost per facility that 

is incurred from reporting under subpart OO. Cost details from Exhibit 6.1 of the most recent 

information collection request for the GHG reporting program (U.S. EPA, 2013) were used to 

determine the subsequent years average cost per facility. These average costs per facility include 

labor costs (i.e., the cost of labor by facility staff to meet the rule’s information collection 

requirements) and non-labor (capital, and operation and maintenance) costs. Additional details of 

the data, methods, and assumptions underlying these costs are documented in the most recent 

information collection request (U.S. EPA, 2013).

Table 5-30 shows first and subsequent year average cost per facility subject to subpart 

OO.

Table 5-30. Annual Average Cost Per Facility Subject to Subpart OO

Subpart

Total Number 

of 

Respondents a

Total Cost

(2011$ per year)

Cost Per Facility

(2011$ per year)

First Year b Subsequent 

Years a First Year b Subsequent Years a

OO –

Industrial GHG 

Suppliers

49 730,000 163,000 4,400 3,300

a This data was extracted from Exhibit 6.1 of the Supporting Statement Part A: Information Collection Request For 

The Greenhouse Gas Reporting Program (U.S. EPA, 2013).

b The first year total cost, and cost per facility, are based on an estimated 167 respondents (in lieu of 49). The 

$730,000 value was determined by adding together the “One-Time Costs” ($6,932,000 / 6,616 x 167) and the “OO. 

Suppliers of Industrial GHG” total cost ($511,000) that are provided in the current burden & cost table in Appendix 

G-3 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting 

Program (U.S. EPA, 2013), and also includes $80.91 from the current burden & cost table identified as “First

Reporting Year” table of Appendix L-2 of the Supporting Statement Part A: Information Collection Request For The 

Greenhouse Gas Reporting Program (U.S. EPA, 2013). The $80.91 is the cost contributed to provisions of 

information on parent companies, NAICS codes, and whether emissions are from cogeneration. These costs were 

updated to 2011 dollars using the Bureau of Labor Statistics Employment Cost Index and the Chemical Engineering 

Plant Cost Index (CEPCI).

By revising the GWP values in subpart A, three additional facilities will be required to 

report under subpart OO. The first year cost for these three facilities will be approximately 

$13,100 per year (3 x $4,370 = $113,100), and the annualized industry wide cost is $10,000 per 

year (3 x $3,300 = $9,900).

5.6.4 Subpart OO Small Entity Impacts (new reporters)

EPA originally assessed the impact of complying with subpart OO requirements on 

entities subject to the rule by calculating a cost to sales ratio for eight enterprise size ranges (i.e., 

all categories, 1 to 20 employees, 20 to 99 employees, 100 to 499 employees, 500 to 749 

employees, less than 500 employees, 750 to 999 employees, and 1,000 to 1,499 employees) 
48

using the ratio of average total annualized mandatory reporting costs to the average 

establishments receipts. For this analysis, because the affected establishments are import and 

export entities with smaller volumes of imported or exported gases, an analysis was performed 

for the smallest size ranges of entities in the NAICS code 42469 (Other chemical and allied 

products, merchant wholesalers). Based on the 2007 economic census database published by 

U.S. Bureau of the Census, the receipts, number of establishments and the average receipts for 

different size entities is summarized in Table 5-31.

Table 5-31. Sales Test for Subpart OO

0- 4 Employees 5-9 Employees 10-19 Employees

Average Receipts for each 

Establishment $ 2,557,209 4,737,209 17,593,574

First Year Cost per Entity $ 4,370 4,370 4,370

Subsequent Year Cost per Entity $ 3,300 3,300 3,300

First Year Sales Test 0.171% 0.092% 0.025%

Subsequent Year Sales Test 0.129% 0.070% 0.019%

The results in Table 5-31 show that the costs for GHG reporting for even the smallest 

facilities subject to subpart OO are well below 1% of the sales for all entities in the NAICS code 

42469. Therefore, there is not a significant economic impact to a substantial number of small 

entities for the facilities subject to subpart OO as a result of the revised GWPs.

5.6.5 Subpart OO (summary of impacts)

Table 5-32 summarizes the impacts of updating the GWP values in Table A-1 to subpart 

A, on new facilities required to report subpart OO emissions.

Table 5-32. New Reporters—Summary of Subpart OO Impacts Due to the Revisions to GWPs

Facility Type

Number of New 

Reporters Due 

to GWP 

Revisions

Incremental 

CO2e Emissions 

for New 

Reporters

(metric tons of 

CO2e per year ) a

Incremental Cost Impact For New 

Reporters

(2011$ per year)

First Year a Subsequent 

Years a

OO –

Industrial GHG Suppliers 3 75,000 13,100 10,000

a Values rounded.

5.6.6 References for Subpart OO

Ottinger, D., 2009. Addition of Bulk Exporters of Fluorinated GHGs, Nitrous Oxide and Carbon Dioxide 

to Threshold Analysis of Industrial Gas Suppliers. Washington, DC: US EPA. See Docket ID: EPA-HQOAR-2008-0508-0230. April 2009.

U.S. EPA, 2009. Additional Methodological Information Supporting Threshold Analysis for Specific 

Source Categories. See Docket ID: EPA-HQ-OAR-2008-0508-0046. March 2009. 
49

U.S. EPA, 2013. Supporting Statement Part A: Information Collection Request For The Greenhouse Gas 

Reporting Program. OMB Control No. 2060-0629. EPA ICR No. 2300.10. May 2013.

5.7 Subpart TT 

Subpart TT applies to industrial waste landfills that accept wastes that have volatile solids 

concentration above 0.5 percent, that have total landfill design capacity greater than or equal to 

300,000 metric tons, and that are located within a facility with GHG emissions equal to or 

greater than 25,000 metric tons of CO2e per year. Therefore, the GHG emissions from an 

industrial waste landfill alone cannot determine the applicability of subpart TT and the GHG 

emissions from the entire facility must be considered. 

In general, industrial waste landfills that meet the GHG reporting criteria are co-located 

with refineries, petrochemical production facilities, pulp and paper mills, and food processing 

facilities. All refineries and petrochemical production facilities are required to report (no 

threshold), and all pulp and paper mills are expected to be above the reporting threshold; 

therefore, all are expected to report under subpart TT if a landfill is present. This impact analysis 

focuses on the additional industrial waste landfills located in food processing facilities that are 

subject to subpart TT due to the revised GWP for CH4 from 21 to 25 and the cost associated with 

these additional landfills subject to subpart TT.

5.7.1 Subpart TT (identifying new reporters)

In the TSD for the Landfill Sector (U.S. EPA, 2009), it was estimated that 200 industrial 

waste landfills would be subject to subpart TT, including 100 landfills co-located with pulp and 

paper mills and 100 landfills co-located with food processing facilities. Because landfill 

emissions are not the primary emissions from pulp and paper mills, the revised CH4 GWP should 

not affect the subpart TT applicability for pulp and paper facilities. 

The number of total food processing facilities has not been updated since the Economic 

Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions: Subparts: T, FF, 

TT, and II (U.S. EPA, 2010a) was developed in June 2010. According to that economic impact 

analysis for subpart TT (U.S. EPA, 2010a), the food processing facilities with the following 

NAICS codes were identified as the potential facilities under subpart TT:

 311611 – Animal (except Poultry) Slaughtering

 311411 – Frozen Fruit, Juice, and Vegetable Manufacturing

 311421 – Fruit and Vegetable Canning

Based on the e-GGRT data for the 2010 reporting year, there are 107 food processing 

facilities reported with the above three NAICS codes. This is close to the original estimate of 100 

food processing facilities in the TSD for the landfill sector (U.S. EPA, 2009). Therefore, the 
50

same food processing facilities information in the TSD for the landfill sector (U.S. EPA, 2009) 

was used to estimate the additional food processing facilities affected by subpart TT due to the 

revised CH4 GWP. 

According to the TSD for the landfill sector (U.S. EPA, 2009), there were 189 food 

processing facilities (based on 1985 data) and 70 of them have GHG emissions between 10,000 

metric tons per year and 25,000 metric tons per year of CO2e based on engineering judgments. 

The list of the food processing facilities is not available. Assuming that CH4 emissions are the 

main GHG emissions from food processing facilities, the food processing facilities with GHG 

emissions between 21,000 metric tons per year and 25,000 metric tons per year of CO2e in the 

TSD are the additional facilities that could be affected by the revised CH4 GWP from 21 to 25. 

Assuming an even distribution of facilities across this range of emissions, the number of food 

processing facilities with CO2e emissions between 21,000 metric tons per year and 25,000 metric 

tons per year is estimated to be 70 x (25,000 – 21,000) / (25,000 – 10,000) = 19 facilities. 

Closed landfills and active landfills that plan to be closed within the next ten years were 

investigated for potential incremental GHG reporting impacts identically to the analysis 

conducted for subpart HH. This analysis found that eight currently closed landfills will 

experience an increased reporting period due to the increased CH4 GWP. No currently active 

landfills that are planned to shut down in the next ten years were expected to incur prolonged 

reporting requirements during the next ten years.

Based on the discussions above, Table 5-33 identifies the number of new subpart TT 

reporters that will become subject to the rule as a result of revisions to the GWPs in Table A-1.

Table 5-33. New Subpart TT Reporters by Type of Industrial Waste Landfill

Type of Industrial Waste Landfill Number of New Reporters Due to GWP Revisions

Located in Pulp and Paper Mills 0

Located in Food Processing Facilities 19

Landfills that will Incur Additional Reporting 

Requirements in the Next Ten Years 8

Total 27

5.7.2 Subpart TT (estimating emissions impacts)

From Table 5-33, there would be 19 additional facilities subject to subpart TT due to the 

revised CH4 GWP. Emissions from these 19 additional facilities were estimated by multiplying 

the number of new affected facilities (19) by the average CH4 generation for each new affected 

facility. The average CH4 generation for each new affected facility is assumed to be (25,000 + 

21,000)/2 x 25/21 = 27,381 metric tons/yr of CO2e. The amount of CO2 equivalent has been 

adjusted using the new GWP for CH4 of 25. Therefore, the total CH4 generation for all new 
51

affected facilities combined is equal to about 520,000 metric tons/yr of CO2e (19 x 27,381 = 

520,239). Table 5-34 identifies the emissions impact from new subpart TT reporters.

Table 5-34. Emissions Impact From New Subpart HH Reporters

Facility Type Incremental CO2e Emissions for New Reporters

(metric tons of CO2e per year )

TT –

Industrial Waste Landfills 520,000

5.7.3 Subpart TT (estimating cost impacts)

Costs were calculated by multiplying the average costs per facility and the number of 

new facilities estimated to be subject to subpart TT (from revising the GWPs). Average cost per 

facility for the first year was calculated by dividing total cost by the number of respondents 

identified in the initial information collection request for subpart TT (U.S. EPA, 2010b). 

Average cost per facility for subsequent years was calculated by dividing total cost by the 

number of respondents identified in the most recent information collection request for the GHG 

reporting program (U.S. EPA, 2013). 

Appendix A to the initial information collection request for subpart TT (U.S. EPA, 

2010b) was used to obtain first year average cost per facility that is incurred from reporting 

under subpart TT. Cost details from Exhibit 6.1 of the most recent information collection request 

for the GHG reporting program (U.S. EPA, 2013) were used to determine the subsequent years 

average cost per facility. These average costs per facility include labor costs (i.e., the cost of 

labor by facility staff to meet the rule’s information collection requirements) and non-labor 

(capital, and operation and maintenance) costs. Additional details of the data, methods, and 

assumptions underlying these costs are documented in the information collection requests (U.S. 

EPA, 2010b and U.S. EPA, 2013).

Table 5-35 shows first and subsequent year average cost per facility subject to subpart 

TT.

Table 5-35. Annual Average Cost Per Facility Subject to Subpart TT

Subpart

Total Number 

of 

Respondents a

Total Cost

(2011$ per year)

Cost Per Facility

(2011$ per year)

First Year b Subsequent 

Years a First Year b Subsequent Years a

TT –

Industrial Waste

Landfills

200 1,182,000 881,000 5,900 4,400

a This data was extracted from Exhibit 6.1 of the Supporting Statement Part A: Information Collection Request For 

The Greenhouse Gas Reporting Program (U.S. EPA, 2013).

b This data was extracted from the “Year 1” table of Appendix A to the initial information collection request for 
52

subpart TT (U.S. EPA, 2010b). These costs were updated to 2011 dollars using the Bureau of Labor Statistics 

Employment Cost Index and the Chemical Engineering Plant Cost Index (CEPCI).

By revising the GWP values in subpart A, 19 additional facilities will be required to 

report under subpart TT. The first year cost for these 19 facilities will be approximately

$112,000 per year (19 x $5,900 = $112,300), and the annualized industry wide cost is 

approximately $83,700 per year (19 x $4,400 = $83,695). An additional eight closed landfills 

will experience an incremental reporting burden over the next ten year period, due to an extended 

number of years reporting would be required; total additional rule implementation costs would 

be $120,400 for these landfills over that ten year period, or an average of $12,000 per year. This 

includes applying extended subsequent year reporting costs for eight currently closed landfills 

that will experience an increased reporting period due to the increased CH4 GWP, as summed 

over a ten-year period. A year-over-year breakdown of these costs is included in Section 5.7.5 

below.

5.7.4 Subpart TT Small Entity Impacts (new reporters)

The small entity economic impact was measured using the “sales tests” approach 

(represented as cost-to-receipt ratios) for NACIS codes associated with the affected subparts in 

the Economic Impact Analysis for Subpart TT (U.S. EPA, 2010a). The same approach is used in 

this analysis for the additional facilities subject to subpart TT due to the revised CH4 GWP. If the 

ratio of rule implementation cost to sales is less than 1%, the impact is not considered to be 

significant (U.S. EPA, 2010a).

Based on the information provided in Tables 5-10 (Number of Establishments) and 5-11

(Receipts by Industry and Enterprise Size, in 2002 dollars) of the Economic Impact Analysis for 

Subpart TT (U.S. EPA, 2010a), the average receipts (sales) for the food processing facilities with 

NAICS codes of 311611, 311411, and 311421 were calculated by dividing the total receipts 

information by the number of establishments for each enterprise size. In addition, the average 

receipts information has been adjusted from 2002 dollars to 2011 dollars based on the consumer 

price index published by Bureau of Labor Statistics. These results are shown in Table 5-36.

Table 5-36. Average Receipts for Each Establishment by Enterprise Size (million, 2011$)

NAICS

NAICS 

Description

SBA Size 

Standard

Owned by Enterprises with:

1-19

Employees

20-99 

Employees

100-499 

Employees

500-749 

Employees

750-999 

Employees

1,000-

1,499 

Employees

311611

Animal (except 

Poultry) 

Slaughtering

500 

employees 1.31 25.38 D D 1,412.28 D

311411

Frozen Fruit, 

Juice, and 

Vegetable 

Manufacturing, 

500 

employees 2.47 45.87 10.46 D 234.82 D
53

Table 5-36. Average Receipts for Each Establishment by Enterprise Size (million, 2011$)

NAICS

NAICS 

Description

SBA Size 

Standard

Owned by Enterprises with:

1-19

Employees

20-99 

Employees

100-499 

Employees

500-749 

Employees

750-999 

Employees

1,000-

1,499 

Employees

and

311421

Fruit and 

Vegetable 

Canning

500 

employees 1.78 20.77 14.77 54.92 139.00 D

Note: D denotes that receipt data was not disclosed.

Although the number of establishment information has been updated in the 2007 

economic census, there is no updated receipts (sales) information for each size of enterprise. 

According to the cost information listed in Table 5-35, the rule implementation costs for subpart 

TT is $5,900 for the first year and $4,400 for the subsequent years (in 2011 dollars). The sales 

tests (cost-to-receipt ratios) results are shown in Table 5-37 for the first year and Table 5-38 for 

the subsequent years.

Table 5-37. Sales Tests for Subpart TT Facilities: First Year

NAICS

NAICS 

Description

SBA Size 

Standard

Owned by Enterprises with:

1-19

Employees

20-99 

Employees

100-499 

Employees

500-749 

Employees

750-999 

Employees

1,000-

1,499 

Employees

311611

Animal (except 

Poultry)

Slaughtering

500 

employees 0.45% 0.02% D D 0.00% D

311411

Frozen Fruit, 

Juice, and 

Vegetable 

Manufacturing

500 

employees 0.24% 0.01% 0.06% D 0.00% D

311421

Fruit and 

Vegetable 

Canning

500 

employees 0.33% 0.03% 0.04% 0.01% 0.00% D

Note: D denotes that receipt data was not disclosed.

Table 5-38. Sales Tests for Subpart TT Facilities: Subsequent Years

NAICS

NAICS 

Description

SBA Size 

Standard

Owned by Enterprises with:

1-19

Employees

20-99 

Employees

100-499 

Employees

500-749 

Employees

750-999 

Employees

1,000-

1,499 

Employees

311611

Animal (except 

Poultry) 

Slaughtering

500 

employees 0.34% 0.02% D D 0.00% D

311411

Frozen Fruit, 

Juice, and 

Vegetable 

Manufacturing

500 

employees 0.18% 0.01% 0.04% D 0.00% D

311421 Fruit and 500 0.25% 0.02% 0.03% 0.01% 0.00% D
54

Table 5-38. Sales Tests for Subpart TT Facilities: Subsequent Years

NAICS

NAICS 

Description

SBA Size 

Standard

Owned by Enterprises with:

1-19

Employees

20-99 

Employees

100-499 

Employees

500-749 

Employees

750-999 

Employees

1,000-

1,499 

Employees

Vegetable 

Canning

employees

Note: D denotes that receipt data was not disclosed.

The results in Tables 5-37 and 5-38 show that the costs for GHG reporting for the 

facilities subject to subpart TT is well below 1% of the sales for all size of Waste Management 

and Remediation Services facilities with a NAICS code of 562. Therefore, it was determined that 

there is not a significant impact on a substantial number of small businesses subject to reporting 

under subpart TT as a result of this action.

5.7.5 Subpart TT (summary of impacts)

Table 5-39 summarize the impacts of updating the GWP values in Table A-1 to subpart 

A, on new facilities required to report subpart TT emissions. The incremental reporting burden is 

provided in year-over-year format in Table 5-40 for both the new reporters and the eight closed 

facilities that would trigger extended reporting requirements over the following ten years.

Table 5-39. New Reporters—Summary of Subpart TT Impacts Due to the Revisions to GWPs

Facility Type

Number of New 

Reporters Due 

to GWP 

Revisions

Incremental 

CO2e Emissions 

for New 

Reporters

(metric tons of 

CO2e per year ) a

Incremental Cost Impact For New 

Reporters

(2011$ per year)

First Year a Subsequent 

Years a

TT –

Industrial Waste Landfills 19 520,000 112,000 83,700

a Values rounded.

The incremental reporting burden is provided in year-over-year format in Table 5-22 for 

both the new reporters and the eight closed facilities that would trigger extended reporting 

requirements over the following ten years. The costs for closed facilities were calculated based 

on applying subsequent year costs ($4,400 per facility) to the facilities identified (see Section 

5.7.1) in each year for which the facility would be subject to extended reporting requirements or 

would be brought into Part 98. No currently active landfills that are planned to shut down in the 

next ten years were expected to incur prolonged reporting requirements during the next ten years.
55

Table 5-40. Summary of Subpart TT Cost Impacts 

$/year 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Landfills 

Closed 

before 

2024

8,800 4,400 4,400 0 8,800 13,200 17,600 23,500 17,600 22,000

New 

Reporters 112,000 83,700 83,700 83,700 83,700 83,700 83,700 83,700 83,700 83,700

Totala120,800 88,100 88,100 83,700 92,500 96,900 101,300 107,200 101,300 105,700

a Total average Incremental Cost Impact for New Reporters and Reporters with Extended Reporting Requirements is $98,580

per year.

5.7.6 References for Subpart TT

U.S. EPA, 2009. Technical Support Document For the Landfill Sector: Proposed Rule For Mandatory 

Reporting Of Greenhouse Gases. See Docket ID: EPA-HQ-OAR-2008-0508-0034. February 4, 2009.

U.S. EPA 2010a. Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions: 

Subparts: T, FF, TT, and II. See Docket ID: EPA-HQ-OAR-2008-0508-2313. June 2010.

U.S. EPA, 2010b. Supporting Statement Part A: Information Collection Request for the Mandatory 

Reporting of Greenhouse Gases from Magnesium Production, Underground Coal Mines, Industrial 

Wastewater Treatment, and Industrial Waste Landfills – Final Rule. OMB Control No. 2060-0647. EPA 

ICR No. 2396.01. July 2010.

U.S. EPA, 2013. Supporting Statement Part A: Information Collection Request For The Greenhouse Gas 

Reporting Program. OMB Control No. 2060-0629. EPA ICR No. 2300.10. May 2013.

6.0 IMPACTS OF OTHER TECHNICAL CORRECTIONS AND AMENDMENTS 

In addition to the amendments to GWPs, EPA is also finalizing technical corrections and 

other clarifications to several subparts in the GHG reporting rule. In this section, we discuss the 

potential burden impacts for facilities and reporters affected by the amendments. The more 

substantive technical corrections, clarifying and other amendments to the GHG reporting rule are 

discussed here. Additional minor corrections are discussed in the memorandum titled “Table of 

2013 Technical Corrections, Clarifying and other Amendments to Certain Provisions of the 

Mandatory Greenhouse Gas Reporting Rule (40 CFR Part 98),” which is available in the 

rulemaking docket. 

6.1 Subpart A - General Provisions

The majority of the revisions to subpart A are associated with changes to additions of 

GWP values and provisions that apply to facilities that would be required to report based on the 

revised GWPs. The remaining amendments to subpart A include adding requirements that 

provide reporters instruction regarding reporting of location, ownership, and facility

identification (i.e., reporting of plant codes). The remaining changes also include revising and 

adding definitions. Except for the amendments related to the GWP changes, the amendments to 

subpart A are not expected to result in any additional burden for facilities subject to the GHG 
56

reporting rule. All of the revisions not related to the GWP changes are either clarifications, or 

require reporting of information that facilities are expected to have readily available (e.g., 

latitude and longitude of the facility). 

6.2 Subpart C - General Stationary Fuel Combustion Sources

For subpart C, EPA is expanding the use of the Tier 1 methodology to be used for Table 

C-1 fuels that are combusted in a unit with a maximum rated heat input capacity greater than 250 

mmBtu/hr, if the fuel provides less than 10 percent of the annual heat input to the unit and the 

use of Tier 4 is not required. Expanding the use of the Tier 1 methodology is expected to reduce 

monitoring burden for facilities that are subject to the requirements of subpart C and combust 

small amounts of secondary fuels. 

EPA is also revising several emission factors and higher heating values (HHVs) for fuels 

in Table C-1 including, but not limited to, coals and coke, liquefied petroleum gases (e.g. 

propane, propylene, ethane, etc.), wood and wood residuals, and biogases. Of the changes to 

emission factors, the change with the largest percent difference (approximately 11 percent) is the 

emission factor for coke (which is also being revised to read “coal coke”). Approximately 1.6 

percent of facilities that reported under subparts C and D for reporting year 2011 indicated using 

coke as a fuel for combustion in addition to other fuels. The majority of coal coke produced (92 

percent) in the United States is used in blast furnaces for the conversion of iron ore into iron

(U.S. EPA, 2001). The emission factor for coal coke is not used in the calculation of CO2

emissions for iron furnaces. Due to the small number of facilities that reported using coke as a 

fuel, and because facilities do not typically use coke as the primary fuel, we do not expect any

additional facilities would be required to report due to an increase in calculated CO2 emissions 

resulting from the increase to the coke emission factor in Table C-1. 

All of the other revisions are either clarifications, or require reporting of information that 

facilities are expected to have readily available (plant code for each power generating unit).

6.3 Subpart H – Cement Production

EPA is requiring annual, facility-wide cement production instead of monthly, kilnspecific cement production for facilities that use a CEMS to measure CO2 emissions. Because 

facilities already expected to track facility-wide cement production for budgeting purposes, we 

do not expect this revision to result in any additional burden for cement production facilities.

6.4 Subpart K – Ferroalloy Production

EPA is finalizing two changes to subpart K. The first change corrects a conversion factor 

in equation K-3 and we do not expect any additional reporter burden as a result. The second 

change requires facilities to report the annual process CH4 emissions from each electric arc 
57

furnace (EAF) used for the production of any ferroalloy listed in Table K-1 of subpart K. 

Because facilities must already monitor and calculate emissions of CH4 from each EAF, we do 

not expect that the changes would impose and additional burden on reporters. The data element 

reflects aggregated annual information that is currently gathered by reporters.

6.5 Subpart L – Fluorinated Gas Production

EPA is extending temporary, less detailed reporting requirements to allow EPA time to 

evaluate concerns raised by producers regarding the potential sensitivity of the more detailed 

reporting required by the 2010 final rule. As the revision would be an extension of existing 

requirements, we do not anticipate any additional reporter burden as a result. 

6.6 Subpart N – Glass Production

In addition to clarify several requirements and equations terms, EPA is revising the 

monitoring methods used to measure carbonate-based mineral mass-fractions to allow for more 

accurate measurement methods and provide flexibility for reporters. EPA is requiring that 

facilities use consensus standards that specify X-ray fluorescence (XRF). To determine if 

requiring XRF methods would impose any additional burden, we compared the cost of the 

currently required methods to methods using XRF. The costs of ASTM D-3682 and D-6349 are 

listed as $165 from Wyoming Analytical Laboratories (WAL). The costs of similar analyses 

using XRF (ASTM D-4326) range from $165 to $195 according to WAL (WAL, 2009). Based 

on the similarity in cost, we do not believe that revising the measurement methods to specify

XRF will impose any additional burden on facilities subject to subpart N.

6.7 Subpart P – Hydrogen Production

EPA is finalizing several amendments to subpart P including adding flexibility for 

monitoring and measurement methodologies and removing redundant reporting requirements. 

EPA is also finalizing changes that clarify rule text and equation terms. None of the amendments 

for subpart P are expected to impose any additional burden on reporters.

6.8 Subpart Q – Iron and Steel Production

EPA is finalizing multiple amendments to subpart Q to clarify certain provisions and 

calculation methods. Two of the revisions may potentially affect the reporting burden for 

facilities covered under subpart Q. First, EPA is including direct reduction furnaces not colocated with an integrated iron and steel manufacturing process, as these furnaces were 

inadvertently excluded from the original rulemaking. Because this change only impacts one 

facility that is already reporting under subpart Q, we do not anticipate this change will impose 

any additional burden on reporters. 
58

Second, EPA is amending Equation Q-5 in subpart Q to account for the use of gaseous 

fuels in EAFs. Because facilities currently determine the mass rate of fuels using the procedures 

in subpart C and must report the annual volume of gaseous fuels, we do not expect that reporters 

will need to collect or record any additional information to account for the use of gaseous fuels 

in equation Q-5 in subpart Q. Therefore, we do not expect any additional burden will be imposed 

on reporters subject to subpart Q.

6.9 Subpart X – Petrochemical Production

EPA is finalizing several substantial changes to subpart X. EPA is requiring reporters 

using CEMS to determine CO2 emissions to use Equation C-10 of subpart C to Part 98 to 

calculate CH4 and N2O emissions from burning process off-gas. We do not expect an increase in 

burden since Tier 4 units can use best available information to estimate fuel use (see 40 CFR 

98.22(c)(4)(i) and 40 CFR 98.33(c)(4)(ii)(C)). 

EPA is also finalizing several changes for those reporters that use the mass balance 

calculation method. First, EPA is allowing flexibility for the source of the carbon measurements 

for feedstocks and products. Next, EPA is allowing the alternative sampling requirements for 

feedstocks and products when the composition is greater than 99.5 percent of a single compound 

to be used during all times that the average monthly concentration is above 99.5 percent. 

Additionally, EPA is allowing the inputs for gaseous feedstock and products to be measured on 

either a mass basis or on a volume basis in Equation X-1. EPA is also allowing facilities to use 

industry standard practices for the analysis of carbon black feedstock oils and carbon black 

products, instead of a specified list of standards currently provided in 40 CFR 98.244(b)(4). We 

do not anticipate any additional burden as a result of these changes since they allow additional 

flexibility for reporters. 

EPA is clarifying the requirements for flares to specify that facilities must conduct 

monitoring and quality assurance in accordance with 40 CFR 98.254(b) through (e) for each flare 

gas flow meter, gas composition meter, and/or heating value monitor that is used to comply with 

40 CFR 98.253(b)(1) through (3), which was EPA’s original intent. We are specifying in the 

final amendments that reports must implement the applicable QA/QC requirements by January 1, 

2015. Since the change is a clarification, we do not expect any additional burden as a result. 

EPA is clarifying the missing data procedures for missing feedstock and product flow 

rates, missing feedstock and product carbon contents, and missing molecular weights for gaseous 

feedstocks and products. EPA is also adding missing data requirements for flares. Because these 

amendments only clarify the existing missing data procedures for subpart X facilities, we do not 

expect these amendments will impose any additional burden on reporters. 
59

Additionally, EPA is finalizing several amendments to reporting requirements. The 

majority of amendments to the reporting requirements are clarifications; however, one particular 

amendment would require facilities to identify combustion units that burned both process off-gas 

and supplemental fuel and that are not part of the petrochemical process unit. EPA is also 

finalizing a requirement for facilities to provide an estimate of the fraction of total CO2

emissions that result from CO2 directly emitted by the petrochemical process unit plus CO2

generated by the combustion of off-gas from the petrochemical process unit (based on 

engineering judgment) if the CEMS monitoring location meets the conditions in 40 CFR 

98.426(b)(2) or (3). Although these are new reporting requirements, facilities would not be 

required to install any additional monitoring equipment or develop any additional monitoring and 

record keeping procedures; therefore, we do not expect these additional reporting requirement to 

significantly increase burden for facilities reporting under subpart X.

6.10 Subpart Z – Phosphoric Acid Production

EPA is finalizing several clarifying amendments to subpart Z, phosphoric acid 

production. Of those amendments, EPA is changing the reporting requirement of the annual 

permitted phosphoric acid production capacity to the annual phosphoric acid production 

capacity. We do not expect this change to impose any additional burden on reporters since the 

information should be readily available in facility records. EPA is also adding a reporting 

requirement to report the number of times missing data procedures were used to estimate the 

CO2 content of the phosphate rock. Again, we do not expect any additional burden for reporters 

as a result of this change because facilities are already required to keep records for estimating 

missing values of CO2 content of phosphate rock per 40 CFR 98.265(a), and no new information 

would need to be collected.

6.11 Subpart AA – Pulp and Paper Production

EPA is correcting emission factors and clarifying the information that must be reported 

under subpart AA. First, EPA is removing the references to site-specific emission factors in 40 

CFR 98.273(a)(3), 40 CFR 98.276(e) and Equation AA-1. EPA is also correcting printing errors, 

inadvertent omissions, and inconsistencies from Table AA-1 and AA-2. We do not anticipate any

additional burden due to these changes since no additional reporting requirements or monitoring 

would be required. 

EPA is also amending the reporting requirement for the annual pulp and/or paper 

production information that must be reported. EPA is clarifying that the annual production 

information must consist of the production of unbleached virgin pulp produced onsite during the 

reporting year and removed the proposed requirement that the production of paper products 

exiting the paper machine(s) during the reporting year, prior to application of any off-machine 
60

coatings be reported. In the final amendments we removed the proposed requirement to report a 

positive (non-zero) value for pulp production. EPA clarified the production reporting 

requirement under 40 CFR 98.276(k) in the “Frequently Asked Questions” section of EPA’s 

supporting website for the GHG reporting rule. In their guidance, EPA specified that facilities 

should report virgin chemical pulp production at the mill separate from the mass of paper 

product exiting all of the paper machine(s) at the mill; therefore, EPA is clarifying the reporting 

requirement and removing the requirement to report paper production. No new reporting or 

monitoring would be required by reporters. As a result, we do not expect the clarification to the 

rule to impose any additional burden on reporters.

6.12 Subpart BB – Silicon Carbide Production

For subpart BB, Silicon Carbide Production, EPA is removing the requirement for 

facilities to report CH4 emissions from silicon carbide process units or furnaces. Additionally, 

EPA is amending subpart BB such that facilities would calculate and report CO2 emissions for 

all process units and furnaces combined, instead of each process unit or production furnace. The 

remaining changes to subpart BB either support these amendments, or provide minor 

clarifications of the rule text. We expect that both of these major changes will reduce the 

reporting burden for facilities subject to subpart BB.

6.13 Subpart DD – Electrical Transmission and Distribution Equipment Use

EPA is finalizing two technical corrections to subpart DD to correct the accuracy and 

precision requirements for weighing cylinders. Instead of scale accuracies of “2 pounds of the 

scale’s capacity,” EPA is revising the rule to be consistent with their original intention of “2 

pounds of true weight.” This accuracy requirement was noted in the technical support document 

to subpart DD, EPA’s response to public comments for subpart DD7, and the preamble to the 

final Part 98 (74 FR 56260, October 30, 2009). In their response to comments, EPA noted that a 

“2 pounds of true weight” requirement would be less burdensome than the 1 percent of true 

weight requirement originally proposed; therefore, we do not expect any added burden would 

result from amending the rule to reflect EPA’s original intent.

6.14 Subpart FF – Underground Coal Mines

EPA finalizing numerous amendments to subpart FF. The majority of the changes include 

terminology revisions that more accurately reflect industry operations, correction of subscript 

errors, and minor clarifications of rule text. More substantially, EPA is including the reporting of 

the following data elements: the moisture correction factor used in the emissions equations; units 

of measure for the volumetric flow rates reported; method of determining the gas composition;

the start date and close date of each well, shaft, or vent hole; the number of days the well, shaft, 

 

7 For more information, refer to http://www.epa.gov/ghgreporting/reporters/subpart/dd.html
61

or vent hole was in operation during the reporting year; the amount of CH4 routed to each 

destruction device; and the identification number assigned by the Mine Safety and Health 

Administration (MSHA). All of these data elements are readily available to reporters and would 

not require additional data collection or monitoring; therefore, we do not expect the changes to 

subpart FF would impose any significant additional burden to covered facilities.

6.15 Subpart HH – Municipal Solid Waste Landfills

For subpart HH, EPA is removing the option to used measured values for the degradable 

organic carbon content in Equation HH-1. EPA is also clarifying that the fraction by volume of 

CH4 in the landfill gas, used in Equation HH-1, should be corrected to zero percent oxygen. 

Additionally, EPA is reducing the measurement frequency for sampling methane concentrations 

from weekly to monthly for the parameter “N” in Equation HH-4. To clarify how to calculate 

methane emissions at landfills with gas collection systems that have multiple measurement 

locations and/or multiple destruction devices, EPA is amending Equations HH-6, HH-7, and HH8 and surrounding text to generalize these equations and to refer to oxidation fractions in Table 

HH-4. EPA is finalizing the oxidation fraction values in Table HH-4 as proposed, with the 

exception that we are limiting the landfills that can use these new methane flux-dependent 

oxidation fractions to those that have cover soils of 24 inches or more over a majority of the 

landfill area containing waste.

EPA is also making several more minor clarifications and amendments including 

removing duplicative reporting requirements. We are finalizing amendments that methane 

recovery calculated using Equation HH-4 and the annual operating hours of the gas collection 

systems are to be reported separately for each measurement location. Because 40 CFR 

98.343(b)(1) and (2) require use of Equation HH-4 separately for each monitoring location, it is 

clear that the methane recovery and the fraction of hours the recovery system operated needs to 

be determined separately for each measurement location as these are separate inputs for 

Equations HH-6 and HH-8 when multiple measurement locations are used. Since this change is a 

clarification, we do not expect any additional burden as a result.

We are making one revision to subpart HH based on comments received on the expansion 

of applicability that will occur in the MSW Landfill sector due to the revision of the GWP for 

methane to the IPCC AR4 value. Specifically, we are providing a very limited exclusion within 

40 CFR 98.340 for certain closed landfills that have not previously had to report under subpart 

HH, but would newly be required to report starting in reporting year 2014 because the amended 

methane GWP causes them to exceed the 25,000 metric tons CO2e emissions threshold for the 

first time. We have added this exclusion to reduce the burden for these closed landfills, who 

would otherwise be required to estimate historical waste quantities and develop their first annual 

report, as discussed in Section 5.4 of this document.
62

Facilities are not required to report any additional data elements, or implement any 

additional monitoring equipment or procedures as a result of these amendments. Therefore, we 

do not expect any additional burden for reporters subject to subpart HH as a result of these 

revisions.

6.16 Subpart LL – Suppliers of Coal-based Liquid Fuels

EPA is finalizing several amendments to subpart LL. In addition to clarifying reporting 

requirements, EPA is removing the requirements at 40 CFR 98.386(a)(1), (a)(5), (a)(13), (b)(1) 

and (c)(1) for each facility, importer, and exporter to report the annual quantity of each product 

or natural gas liquid on the basis of the measurement standards method or industry standard 

practice used. We expect a reduction in burden for reporters subject to subpart LL since EPA is 

removing reporting requirements from the rule.

6.17 Subpart MM – Suppliers of Petroleum Products

In addition to several minor correction and clarifications, EPA is finalizing several 

substantial technical corrections for subpart MM. First, EPA is amending the equipment 

calibration requirements for petroleum products suppliers to be consistent with other Part 98 

calibration requirements to allow for postponement of calibrations for units and processes that 

operate continuously with infrequent outages and therefore provide flexibility for reporters 

meeting the equipment calibration requirements. Next, EPA is removing the requirements of 40 

CFR 98.396(a)(1), (a)(5), (a)(13), (b)(1) and (c)(1) for each facility, importer, and exporter to 

report the annual quantity of each petroleum product or natural gas liquid on the basis of the 

measurement standard method or industry standard practice used. EPA is also removing the 

requirements of 40 CFR 98.396(a)(4), (a)(8), (a)(15), (b)(4), and (c)(4) for each facility, 

importer, and exporter to report a complete list of methods used to measure the annual quantities 

reported for each product or natural gas liquid. In another step to reduce recordkeeping and 

reporting burden, the reporting requirements for crude oil at 40 CFR 98.396(a)(20) are changed

to require only the annual quantity of crude oil. EPA is also eliminating the requirement to 

measure the API gravity of each batch of crude oil at 40 CFR 98.394(d). EPA is adding and 

revising several definitions and revising the default density and emission factors in Table MM-1 

in subpart MM. We expect that the changes to subpart MM will provide additional flexibility for 

reporters and reduce the reporting and recordkeeping burden for those facilities required to report 

under subpart MM.

6.18 Subpart NN – Suppliers of Natural Gas Liquids

EPA is finalizing several technical corrections to subpart NN. In addition to minor 

changes, EPA is finalizing several amendments that may affect the reporting burden of facilities 

subject to subpart NN. First, EPA is amending the definition of Local Distribution Companies 
63

(LDS) to clarify that for LDCs that operate in multiple states, the operations in each state are 

considered a separated LDC. EPA is also clarifying that interstate and intrastate pipelines 

delivering natural gas either directly to major industrial users or to farm taps upstream of the 

LDC inlet are not included in the definition of an LDC. We do not expect these clarifications to 

impose any additional burden on reporters. In “Q286” of the “Frequently Asked Questions” 

section of EPA’s supporting website for the GHG reporting rule, EPA initially clarified its intent 

that the owner/operator of each LDC that is regulated as a separate operating company by State 

public utility commissions or that operate as independent municipally–owned distribution 

systems must submit an annual report. Therefore, the clarifications are a follow-up to previous 

guidance and we do not expect any additional owners/operators would be required to report as a 

result of the change. 

EPA is also changing the calculation and reporting requirements that require LDCs to 

report the annual volume of natural gas delivered to each meter registering supply equal to or 

greater than 460,000 million standard cubic feet (Mscf). EPA is finalizing a requirement that if 

the LDC knows based on readily available information that multiple meters serve one large end 

user facility (defined in the final rule as a facility receiving a total of greater than 460,000 Mscf 

during the year), the LDC would be required to report these deliveries per facility rather than per 

meter. If the LDC does not know if the series of meters serve an individual end user or multiple 

facilities, the LDC may continue to report deliveries to individual meters. Because LDCs would 

be able to report on a per facility, rather than per meter basis, we expect a reduction in the 

reporting burden as a result of this change. 

EPA is amending part of the calculation methodology in subpart NN. Subpart NN 

currently requires the use of a single emission factor for all types of gas streams accounted for in 

Equation NN-5. Because the characteristics of these streams may differ, EPA is replacing 

equation NN-5 with two equations, NN-5a and NN-5b. The greenhouse gas quantity associated 

with the net amount of natural gas that is placed into or removed from storage during the year is 

to be calculated using equation NN-5a. Emissions that would result from the combustion or 

oxidation of natural gas received by the LDC that bypassed the city gate are calculated using 

Equation NN-5b, which allows the use of different emission factors for different streams of gas. 

Additionally, EPA is changing Equation NN-6 to incorporate the two NN-5 equations. Reporters 

would only be required to modify their calculation methodology and would not be required to 

install any additional monitoring equipment. Therefore, we do not expect any additional burden 

on facilities required to report under subpart NN as a result of these changes.

EPA is also requiring the reporting of the quantity of o-grade, y-grade, and other types of 

bulk natural gas liquids (NGLs) received, and the quantity not fractionated, but supplied 

downstream. We do not anticipate that reporters would be required to purchase or install any new 
64

monitoring equipment as a result of these reporting requirements since (per 40 CFR 

98.404(a)(1)) fractionators and LDCs are required to determine quantities using methods in 

common use in the industry for billing purposes as audited under existing Sarbanes Oxley

regulation. 

6.19 Subpart QQ – Importers of Exporters of Fluorinated Greenhouse Gases Contained 

in Pre-Charged Equipment of Closed Cell Foams

EPA is finalizing multiple revisions to subpart QQ. In addition to minor corrections and 

clarifications, EPA is removing the following reporting requirements: 40 CFR 98.436(a)(5), 

(a)(6)(iv), (b)(5), and (b)(6)(iv). We expect that the removal or reporting requirements will 

alleviate reporting burden for facilities required to report under subpart QQ. 

6.20 Subpart RR – Geologic Sequestration of Carbon Dioxide

In addition to minor corrections and clarifications to subpart RR, EPA is adding a 

reporting requirement for facilities to report the standard or method used to calculate the mass or 

volume of contents in containers that is redelivered to another facility without being injected into 

the well. The data element does not require additional data collection or monitoring from 

reporters, and as it is not a significant change. Therefore, we do not expect that this amendment 

would add burden to reporting entities.

6.21 Subpart TT – Industrial Waste Landfills

EPA is finalizing multiple changes to subpart TT. EPA is revising definitions in Equation 

TT-1 and TT-7 and to correct Equation TT-7 by deleting an erroneous term. EPA is also making 

a change to clarify that the number of waste streams for which Equation TT-1 is used includes 

the number of "Inert" waste streams disposed of in the landfill. Additionally, EPA is expanding

the provisions to determine volatile solids concentration for historically managed waste streams 

so that they may also be used for determining a site-specific DOC value for historically managed 

waste streams. EPA is also eliminating duplicative reporting requirements and to clarify the 

requirements for reporters when using Equations TT-4a or TT-4b. EPA is finalizing amendments

to revise the oxidation fraction default value (“OX”) in Equation TT-6 to reference the new

default oxidation factors in Table HH-4; however, we have revised the amendments to limit the 

new oxidation factors to landfills with soil covers of at least 24 inches for a majority of the 

landfill area containing waste, and to allow the continued use of the 0.10 default oxidation factor 

for facilities that do not meet these requirements. EPA is also making changes to Table TT-1 to 

include the DOC default value of 0.09 for “Industrial Sludge,” and the corresponding k-values. 

None of the changes to subpart TT would require any additional monitoring or recordkeeping 

and reporting by facilities, therefore we do not anticipate any additional burden as a result of the 

changes to subpart TT.
65

6.22 Subpart UU – Injection of Carbon Dioxide

EPA is finalizing technical amendments to subpart UU. In particular, EPA is adding two 

reporting requirements. First, reporters would be required to report the purpose of CO2 injection. 

Second, facilities would be required to report the standard or method used to calculate the 

parameters for CO2 received in containers. Neither of these reporting requirements would require 

facilities to collect any additional data or install and operate any additional monitoring 

equipment. As a result, we do not expect the changes would impose any additional significant 

burden on facilities required to report un_)der subpart UU. 

6.23 Additional Subparts with Corrections

EPA is finalizing several changes to subparts E, G, O, S, V, Y, II, PP, and SS; however, 

all of the changes are clarifications and/or corrections for consistency throughout the subparts. 

Therefore, we do not expect any additional burden for facilities subject to the reporting 

requirements of subpart E, G, O, S, V, Y, II, PP, and SS as a result of these changes.

6.24 References for Section 6

U.S. EPA, 2001. National Emission Standards for Hazardous Air Pollutants (NESHAP) for Coke Ovens: 

Pushing, Quenching, and Battery Stacks – Background Information for Proposed Standards. EPA-453/R01-006. Available at: http://www.epa.gov/ttn/atw/coke2/coke2p_bid.pdf. 

WAL, 2009. Wyoming Analytical Laboratories, Inc. Prices as of Spring 2009. Available at: 

http://www.wal-lab.com/DownloadFiles/CementFlyAsh%20SoilsOverb.pdf. 
Appendix A

GWPs –Revisions to Table A-1
A-1

Appendix A: GWPs Revisions to Table A-1 of Subpart A

Name CAS No. Chemical Formula

Table A-1 

Global 

Warming 

Potential 

(100 yr.)

New or 

Revised

Global 

Warming 

Potentials 

(100 yr.) Increase

% 

Increase

Carbon Dioxide CO2 1 1 -- --

Methane 74-82-8 CH4 21 25 4 19%

Nitrous oxide 10024–97–2 N2O 310 298 -12 -4%

HFC–23 75–46–7 CHF3 11,700 14,800 3,100 26%

HFC–32 75–10–5 CH2F2 650 675 25 4%

HFC–41 593–53–3 CH3F 150 92 -58 -39%

HFC–125 354–33–6 C2HF5 2,800 500 -2,300 -82%

HFC–134 359–35–3 C2H2F4 1,000 1,100 100 10%

HFC–134a 811–97–2 CH2FCF3 1,300 1,430 130 10%

HFC–143 430–66–0 C2H3F3 300 353 53 18%

HFC–143a 420–46–2 C2H3F3 3,800 4,470 670 18%

HFC–152 624–72–6 CH2FCH2F 53 53 0 0%

HFC–152a 75–37–6 CH3CHF2 140 38 -102 -73%

HFC–161 353–36–6 CH3CH2F 12 12 0 0%

HFC–227ea 431–89–0 C3HF7 2,900 3,220 320 11%

HFC–236cb 677–56–5 CH2FCF2CF3 1,340 1,340 0 0%

HFC–236ea 431–63–0 CHF2CHFCF3 1,370 1,370 0 0%

HFC–236fa 690–39–1 C3H2F6 6,300 9,810 3,510 56%

HFC–245ca 679–86–7 C3H3F5 560 693 133 24%

HFC–245fa 460–73–1 CHF2CH2CF3 1,030 1,030 0 0%

HFC–365mfc 406–58–6 CH3CF2CH2CF3 794 794 0 0%

HFC–43–10mee 138495–42–8 CF3CFHCFHCF2CF3 1,300 1,640 340 26%

Sulfur hexafluoride 2551–62–4 SF6 23,900 22,800 -1,100 -5%

Trifluoromethyl 

sulphur pentafluoride 373–80–8 SF5CF3 17,700 17,700 0 0%

Nitrogen trifluoride 7783–54–2 NF3 17,200 17,200 0 0%

PFC–14 

(Perfluoromethane) 75–73–0 CF4 6,500 7,390 890 14%

PFC–116 

(Perfluoroethane) 76–16–4 C2F6 9,200 12,200 3,000 33%

PFC–218 

(Perfluoropropane) 76–19–7 C3F8 7,000 8,830 1,830 26%

Perfluorocyclopropane 931–91–9 C-C3F6 17,340 17,340 0 0%

PFC–3–1–10 

(Perfluorobutane) 355–25–9 C4F10 7,000 8,860 1,860 27%

Perfluorocyclobutane 115–25–3 C-C4F8 8,700 10,300 1,600 18%

PFC–4–1–12 

(Perfluoropentane) 678–26–2 C5F12 7,500 9,160 1,660 22%

PFC–5–1–14 355–42–0 C6F14 7,400 9,300 1,900 26%
A-2

Appendix A: GWPs Revisions to Table A-1 of Subpart A

Name CAS No. Chemical Formula

Table A-1 

Global 

Warming 

Potential 

(100 yr.)

New or 

Revised

Global 

Warming 

Potentials 

(100 yr.) Increase

% 

Increase

(Perfluorohexane)

PFC–9–1–18 306–94–5 C10F18 7,500 7,500 0 0%

HCFE–235da2 

(Isoflurane) 26675–46–7 CHF2OCHClCF3 350 350 0 0%

HFE–43–10pccc (H–

Galden 1040x) E1730133

CHF2OCF2OC2F4OC

HF2 1,870 1,870 0 0%

HFE–125 3822–68–2 CHF2OCF3 14,900 14,900 0 0%

HFE–134 1691–17–4 CHF2OCHF2 6,320 6,320 0 0%

HFE–143a 421–14–7 CH3OCF3 756 756 0 0%

HFE–227ea 2356–62–9 CF3CHFOCF3 1,540

HFE–236ca12 (HG–10) 78522–47–1 CHF2OCF2OCHF2 2,800 2,800 0 0%

HFE–236ea2 

(Desflurane) 57041–67–5 CHF2OCHFCF3 989 989 0 0%

HFE–236fa 20193–67–3 CF3CH2OCF3 487 487 0 0%

HFE–245cb2 22410–44–2 CH3OCF2CF3 708 708 0 0%

HFE–245fa1 84011–15–4 CHF2CH2OCF3 286 286 0 0%

HFE–245fa2 1885–48–9 CHF2OCH2CF3 659 659 0 0%

HFE–254cb2 425–88–7 CH3OCF2CHF2 359 359 0 0%

HFE–263fb2 460–43–5 CF3CH2OCH3 11 11 0 0%

HFE–329mcc2 67490–36–2 CF3CF2OCF2CHF2 919 919 0 0%

HFE–338mcf2 156053–88–2 CF3CF2OCH2CF3 552 552 0 0%

HFE–338pcc13 (HG–

01) 188690–78–0 CHF2OCF2CF2OCHF2 1,500 1500 0 0%

HFE–347mcc3 28523–86–6 CH3OCF2CF2CF3 575 575 0 0%

HFE–347mcf2 E1730135 CF3CF2OCH2CHF2 374 374 0 0%

HFE–347pcf2 406–78–0 CHF2CF2OCH2CF3 580 580 0 0%

HFE–356mec3 382–34–3 CH3OCF2CHFCF3 101 101 0 0%

HFE–356pcc3 160620–20–2 CH3OCF2CF2CHF2 110 110 0 0%

HFE–356pcf2 E1730137 CHF2CH2OCF2CHF2 265 265 0 0%

HFE–356pcf3 35042–99–0 CHF2OCH2CF2CHF2 502 502 0 0%

HFE–365mcf3 378–16–5 CF3CF2CH2OCH3 11 11 0 0%

HFE–374pc2 512–51–6 CH3CH2OCF2CHF2 557 557 0 0%

HFE–449s1 (HFE–

7100) Chemical blend

163702–07–6

163702–08–7

C4F9OCH3

(CF3)2CFCF2OCH3 297 297 0 0%

HFE–569sf2 (HFE–

7200) Chemical blend

163702–05–4 

163702–06–5

C4F9OC2H5

(CF3)2CFCF2OC2H5 59 59 0 0%

Sevoflurane 28523–86–6 CH2FOCH(CF3)2 345 345 0 0%

HFE–356mm1 13171–18–1 (CF3)2CHOCH3 27 27 0 0%
A-3

Appendix A: GWPs Revisions to Table A-1 of Subpart A

Name CAS No. Chemical Formula

Table A-1 

Global 

Warming 

Potential 

(100 yr.)

New or 

Revised

Global 

Warming 

Potentials 

(100 yr.) Increase

% 

Increase

HFE–338mmz1 26103–08–2 CHF2OCH(CF3)2 380 380 0 0%

(Octafluorotetramethylene)hydroxymethyl 

group NA X-(CF2)4CH(OH)-X 73 73 0 0%

HFE–347mmy1 22052–84–2 CH3OCF(CF3)2 343 343 0 0%

Bis(trifluoromethyl)-

methanol 920–66–1 (CF3)2CHOH 195 195 0 0%

2,2,3,3,3-

pentafluoropropanol 422–05–9 CF3CF2CH2OH 42 42 0 0%

PFPMIE NA

CF3OCF(CF3)CF2OCF

2OCF3 10,300 10,300 0 0%