2011 Technical Corrections, Clarifying and Other Amendments to the Mandatory Reporting of Greenhouse Gases Rule:

Subparts A, W, FF, II, OO, RR and TT Economic Impacts Memo

May 13, 2011

The 2009 final GHG reporting rule (2009 final rule) was signed by EPA Administrator Lisa Jackson on September 22, 2009 and published in the Federal Register on October 30, 2009 (74 FR 56260, October 30, 2009). The 2009 final rule, which became effective o n December 29, 2009, included reporting of GHGs from various facilities and suppliers, consistent with the 2008 Consolidated Appropriations Act.

Subsequent notices were published in 2010 finalizing the requirements for subparts FF, II, and TT (75 FR 3973 6, July 12, 2010), subpart W (75 FR 74458, November 20, 2010 ) , and subpart RR (75 FR 75060, December 1, 2010). Subpart OO, which was promulgated as part of the 2009 final rule was also revised in 2010 (75 FR 79092, December 17, 2010). The source categori es in 40 CFR part 98 cover approximately 85

- 90 percent of U.S. GHG emissions through reporting by direct emitters, as well as suppliers of certain products that would result in GHG emission when released, used, or oxidized, and those that geologically sequ ester or otherwise inject CO2 underground.

EPA is proposing to amend specific provisions in 40 CFR part 98, subparts A, W, FF, II, OO,
RR and TT to correct certain technical and editorial errors that have been identified since promulgation and to clarify or propose amendments to certain provisions that have been the subject of questions from reporting entities. These proposed changes include additional information to clarify compliance obligations, correct data reporting elements so they more closely con form to the information used to perform emission calculations, and make other
corrections and amendments.

After review of the technical corrections and consultation with technical experts who developed the original cost and economic analysis, EPA has deter mined that t he proposed rule amendments will not impose any new requirement s that are not currently required by the rules promulgated on October 30, 2009 (i.e., calculating and reporting annual GHG emissions) or alter the cost2

estimates contained in the or iginal analyses

. As a result, the original national cost estimates remain $208.7 million in the First Year and $119.9 million in subsequent years.

Table 1. Summary of Cost Changes Associated with the Proposed Notice of Reconsideration (million, 2006$)

R ulemaking First Year Cost Estimate Subsequent

Year Cost Estimate
Mandatory Reporting Rule National Cost Estimate (Private and Public) $132.0 $89.1 Revisons to certain provisions of the Mandatory Reporting of Greenhouse Gases (GHG) Rule

Review of revisions $2.5 $0.0

Subpart NN Change

- $3.6

- $2.5

Subpart C Change

- $1.7

- $1.0
Reporting of Corporate Parent, NAICS Code, and Co

- Generation Information $0.9 $0.5

Subpart W $6 2.9 $20

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Subpart T, FF, II, TT $7.0 $5.5

F

- Gas: Subparts I, L,DD, QQ, SS $7.6 $7.2

Subparts RR and UU: $1.1 $1.0

Total National Cost Estimate (All Final Rules) $ 208.7 $1 19.9

Proposed Technical Corrections (This Action) $0.0 $0.0

Revised National Cost Estimate $208 .7 $119

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