SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Greenhouse Gas Reporting Rule: 2014 Revisions and Confidentiality Determinations for 

Petroleum and Natural Gas Systems; Final Rule

(40 CFR Part 98, subpart W)

November 2014

Part A of the Supporting Statement

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

Recordkeeping and Reporting Requirements for 2014 Revisions to Petroleum and Natural 

Gas Systems (40 CFR part 98, Subpart W). The OMB control number is 2060-0629 and the EPA

ICR tracking number is 2300.15.

1(b) Short Characterization

In response to the FY2008 Consolidated Appropriations Act (H.R. 2764; Public Law 

110-161) and under authority of the Clean Air Act (CAA), EPA finalized the Greenhouse Gas 

Reporting Rule (74 FR 56260; October 30, 2009). The Greenhouse Gas Reporting Rule is 

referred to as 40 CFR Part 98 (Part 98) and implementation of Part 98 is referred to as the 

Greenhouse Gas Reporting Program (GHGRP). This supporting statement addresses information 

collection activities that will be imposed by “Greenhouse Gas Reporting Rule: Revisions and 

Confidentiality Determinations for Petroleum and Natural Gas Systems; Final Rule”.

Part 98, which became effective on December 29, 2009, requires that certain facilities 

and suppliers emitting above certain threshold levels of carbon dioxide (CO2) equivalent (CO2e) 

monitor and report emissions of greenhouse gases (GHGs). A subsequent rule was published on 

November 30, 2010 finalizing the requirements for the petroleum and natural gas systems source 

category (hereafter referred to as “subpart W”) at 40 CFR part 98, subpart W (75 FR 74458).

In this final amendatory package for subpart W, EPA is clarifying terms and definitions, 

and correcting technical and editorial errors that have been identified during the course of 

implementation; these revisions are not expected to substantively affect respondent burden. EPA 

is also revising calculation methods, and amending monitoring and data reporting requirements; 

some of these revisions may affect respondent burden. See Section 4(b) and Appendix A for a 

complete list of revisions to the reporting requirements.

Potential respondents are owners or operators of petroleum and natural gas systems that 

meet the requirements of §98.2(a)(2) and the reporting thresholds of §98.231. Respondents are

required to report data elements according to §98.236, and maintain records according to 

§98.237 and other source categories, as applicable.

Page 1 November 2014
Approximately 2,900 respondents will be subject to the regulation and this rulemaking is 

expected to increase labor costs for subpart W facilities. Compared with the estimated 

respondent burden identified in the information collection for the GHGRP currently approved by 

the Office of Management and Budget (OMB), this information collection will result in an 

increase in annual burden of approximately 7,700 hours and $603,000 (labor costs), as shown in 

Section 6.

Page 2 November 2014
2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

The FY2008 Consolidated Appropriations Act, signed into law on December 26, 2007,

directed EPA to “develop and publish a draft rule not later than 9 months after the date of 

enactment of this Act, and a final rule not later than 18 months after the date of enactment of this 

Act, to require mandatory reporting of greenhouse gas emissions above appropriate thresholds in 

all sectors of the economy of the United States.” 

As stated in the October 30, 2009 preamble to Part 98 (74 FR 56260), CAA section 

114(a)(1) authorizes the Administrator to require emissions sources, persons subject to the CAA, 

or persons whom the Administrator believes may have necessary information to report emissions 

and provide such other information the Administrator requests for the purposes of carrying out 

any provision of the CAA.

Therefore, the EPA is finalizing this information collection under the Clean Air Act 

(CAA) authority provided in CAA section 114.

2(b) Use/Users of the Data

The GHGRP collects information from facilities that directly emit GHGs and from 

suppliers of products that release GHGs if combusted, oxidized, or used. The comprehensive 

GHG data reported directly from large facilities and suppliers across the country are accessible to 

the public at: http://ghgdata.epa.gov/ghgp/main.do. Reporting entities generally use uniform 

methods for estimating emissions, which enables data to be compared and analyzed. 

Data collection in the GHGRP complements the Inventory of U.S. Greenhouse Gas 

Emissions and Sinks (Inventory) and provides a critical tool for communities to identify nearby 

sources of GHGs and provide information to state and local governments.

The standardization of GHG data provides businesses with the necessary information to 

benchmark themselves against similar facilities, better understand their relative standing within 

their industry, and achieve and disseminate their environmental achievements. Businesses and 

other innovators can use the data to determine their GHG footprints, find cost- and fuel-saving 

efficiencies that reduce greenhouse gas emissions (e.g., through energy audits or other forms of 

assistance), and foster technologies to protect public health and the environment. 

Generally, the facility-specific GHG emission data improve the understanding of the 

factors that influence GHG emission rates as well as the actions that facilities take to reduce 

emissions. The facility-based data can be aggregated to the corporate level in order to track 

emission trends from industries, within industries, and across industries over time, particularly in 

response to policies and potential regulations. 

Specifically, Subpart W data can be used to complement atmospheric GHG studies and 

inform updates to emission inventories. Various activity data are collected that can be used to 

improve understanding of the occurrence of emissions from a variety of sources. 

Page 3 November 2014
3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION

CRITERIA

3(a) Nonduplication

The information to be collected under the revisions includes 247 new data elements and 

13 substantially revised data elements (refer to section 4(b) and Appendix A for a list of these 

data elements). These new and substantially revised data elements consist primarily of quantities 

that provide information on the activity level at the facility and other process information that 

will provide key information for verification, including confirming that emissions are appropriate 

for a given activity-level and estimating expected emissions based on data provided. These new 

and substantially revised reporting elements for subpart W are similar to the types of industry 

data already being collected under the GHGRP. EPA has evaluated the types of industry data 

collected under Part 98, and concluded that they do not duplicate other information collections, 

as described below.

In developing the GHGRP, EPA reviewed monitoring methods, including:

• Federal programs within the United States, such as the Inventory, the U.S. 

Department of Energy’s (DOE’s) Energy Information Administration’s (EIA’s) 

1605b program, the Acid Rain Program, EPA Natural Gas STAR Program, and 

voluntary GHG partnership programs;

• State and regional GHG reporting programs, such as The Climate Registry, the 

Regional Greenhouse Gas Initiative, the Western Regional Air Partnership, and 

programs in several states including California, New Mexico, Connecticut, and New 

Jersey;

• Reporting protocols developed by nongovernmental organizations, such as the World 

Resources Institute/World Business Council for Sustainable Development; 

• Programs from industrial trade organizations, such as the Interstate Natural Gas 

Association of America’s GHG Emission Estimation Guidelines, the American 

Petroleum Institute’s Compendium of GHG Estimation Methodologies for the Oil and 

Gas Industry, and the World Business Council for Sustainable Development’s 

Cement Sustainability Initiative’s CO2 Accounting and Reporting Standard for the 

Cement Industry; and

• IPCC Guidelines for National Greenhouse Gas Inventories.

Many of these programs collect different or additional data as compared to the GHGRP

and this rulemaking. For example, state programs may include different data elements to support 

other programs (e.g., offsets). While some programs collect similar information on GHG 

emissions, the Agency has determined that the GHGRP supplements and complements, rather 

than duplicates, existing programs’ data. Further, EPA has made significant efforts over the past 

Page 4 November 2014
four years to facilitate the reporting in the event a single entity has to report both the federal and 

state level. For example, EPA has supported efforts by the California Air Resources Board to 

harmonize the reporting of information under California’s Global Warming Solutions Act, AB32 

with EPA’s GHGRP. The product of the collaboration is referred to as California Electronic 

Greenhouse Gas Reporting Tool, or Cal e-GGRT.

Documentation of EPA’s review of GHG monitoring protocols used by federal and state 

voluntary and mandatory GHG programs as well as GHG reporting rules can be found in the 

docket at EPA-HQ-OAR-2008-0508-0056. For further discussion on the relationship of the 

GHGRP to other programs, please refer to the preambles of the proposed and final GHG 

reporting rules (which can be found in the docket at EPA-HQ-OAR-2008-0508), the June 6, 

2008 memorandum entitled Review of Existing Programs (which can be found in the docket at 

EPA-HQ-OAR-2008-0508-0052), and the January 27, 2009 memorandum entitled Review of 

Existing State Greenhouse Gas Reporting Rules (which can be found in the docket at EPA-HQOAR-2008-0508-0054). 

As noted in the current ICR for the GHGRP, a number of programs at the state, tribal, 

territorial, and local level require emission sources in their respective jurisdictions to monitor and 

report GHG emissions. To reduce burden on reporters and program agencies, the Agency plans 

to share reported data, with the exception of any information determined to be Confidential 

Business Information (CBI), with relevant agencies or approved entities using, where practical, 

shared tools, and infrastructure.

Based on this evaluation, this information collection request does not duplicate other 

information collections.

3(b) Public Notice Required Prior to Information Collection Request (ICR) Submissions to 

OMB

A public notice of this collection is provided in the Federal Register notice of 

“Greenhouse Gas Reporting Rule: 2014 Revisions and Confidentiality Determinations for 

Petroleum and Natural Gas Systems; Final Rule.”

3(c) Consultations

Early in the development process of the GHGRP, EPA conducted a proactive 

communications outreach program to inform the public about the rule development effort. EPA 

solicited input and maintained an open-door policy for those interested in discussing the 

rulemaking. Since January 2008, EPA staff has held more than 100 meetings with stakeholders, 

including the following:

• Trade associations and firms in potentially affected industries/sectors;

• State, local, and tribal environmental control agencies and regional air quality 

planning organizations;

Page 5 November 2014
• State and regional organizations already involved in GHG emissions reporting, 

such as The Climate Registry, California Air Resources Board, and the Western 

Climate Initiative; and

• Environmental groups and other nongovernmental organizations.

EPA also has met with federal agencies, including the U.S. Department of Energy and the 

U.S. Department of Agriculture, which have programs relevant to GHG emissions.

On April 10, 2009 (74 FR 16448), EPA proposed the GHGRP. EPA held two public 

hearings, and received more than 16,000 written public comments. The public comment period 

ended on June 9, 2009. Comments related to Subpart W were received from more than 80 

entities with over 1,200 pages of comments, recommendations, and alternatives for 

consideration. Details about these meetings and the responses to comments are available in the 

docket (EPA-HQ-OAR-2009-0923). Following promulgation of the final 2010 subpart W rule, 

EPA finalized actions revising subpart W (76 FR 22825, April 25, 2011; 76 FR 59533, 

September 27, 2011; 76 FR 80554, December 23, 2011; 77 FR 51477, August 24, 2012; 78 FR 

25392, May 1, 2013; 78 FR 71904, Nov. 29, 2013). 

In the current action, the EPA is revising some of the GHG reporting requirements for the 

petroleum and natural gas systems source category. The changes include revising calculation 

methods, amending monitoring and data reporting requirements, clarifying terms and definitions, 

and correcting technical and editorial errors identified during the course of implementation. The 

revisions were identified from the verification of annual reports, review of Best Available 

Monitoring Method (BAMM) request submittals, and questions raised by reporting entities. In 

conjunction with this action, we are finalizing confidentiality determinations for the new and 

substantially revised data elements contained in these amendments; we are also revising the

confidentiality determination for one existing data element. 

3(d) Effects of Less Frequent Collection

The frequency for reporting emissions information to EPA under the GHGRP was 

originally established to minimize the burden on owners and operators of affected facilities, 

while ensuring that the GHGRP collects facility-specific data of sufficient quality to achieve the 

Agency’s objectives. The GHGRP requires annual reporting, except for a limited number of 

facilities that are already subject to more frequent reporting requirements. This reporting 

frequency remains the same in these revisions to Part 98.

Annual reporting will ensure that data are verified and made available to the public, as 

authorized by the CAA. If the information collection were not carried out on this schedule, the 

Agency will not be able to develop an informed tracking system of trends in GHG emissions 

across the country. 

3(e) General Guidelines

This collection is consistent with all OMB guidelines under 5 CFR 1320.5.

Page 6 November 2014
3(f) Confidentiality

Data collected under the GHGRP must be made available to the public unless the data 

qualify for CBI treatment under the CAA and EPA regulations. The CAA precludes “emission 

data” from being treated as confidential. For data reported under the CAA that are not emission 

data, EPA typically makes CBI determinations under 40 CFR 2.301 on a case-by-case basis. Due 

to the large number of entities reporting under the GHGRP and the large number of data 

reporting elements, EPA previously concluded that case-by-case determinations will not result in 

timely release of emission and other non-CBI data (see proposed CBI rule, July 7, 2010, 75 FR 

39094 and final CBI rule, May 26, 2011, 76 FR 30782). For this reason, the EPA has made CBI 

determinations for most data reporting elements through a series of rulemakings that specify 

which data reporting elements in Part 98: (1) are CBI, (2) are non-CBI, and (3) are emission data 

(i.e., ineligible for CBI protection). All data determined by EPA to be CBI are safeguarded in 

accordance with regulations in 40 CFR Chapter 1, Part 2, Subpart B. The CBI determinations for 

subpart W data reporting elements (excluding data reporting elements used as inputs to emission 

calculations) were made in 77 FR 48072, August 13, 2012. The reporting of data elements used 

as inputs to emission calculations were addressed in 79 FR 63750, October 24, 2014. In the 

current action, the EPA is finalizing confidentiality determinations for the new and substantially 

revised data elements contained in these amendments; we are also revising a confidentiality 

determination for one existing data element.

3(g) Sensitive Questions

The revisions to reporting or recordkeeping requirements in the revisions to Part 98 do 

not include sensitive questions.

Page 7 November 2014
4. THE RESPONDENTS AND THE INFORMATION REQUESTED

The respondents in this information collection include owners and operators of petroleum 

and natural gas systems facilities that must report their GHG emissions to EPA to comply with 

Part 98, subpart W. This section provides a list of industry sectors that must comply with the 

rule, the data elements required of program participants, and the activities in which participants 

must engage to collect, assess, calculate, and in some cases submit the required data elements. 

4(a) Respondents/North American Industrial Classification System (NAICS) Codes

The revisions to Part 98 affect facilities subject to subpart W. Reporting facilities for 

Subpart W include, but are not limited to, those operating one or more units that exceed the CO2e 

threshold for the industry sectors listed below (and listed in Table A-3 of 40 CFR 98.2(a)(1)). 

Industry sectors are listed by the corresponding subpart of Part 98 and NAICS code for 

reference. The NAICS codes are not exhaustive, but rather provide a list of facilities likely to be 

affected.

Part and Subpart NAICS code(s)

40 CFR Part 98

W. Petroleum and 

Natural Gas Systems

486210 Pipeline transportation of natural gas.

221210 Natural gas distribution.

211111 Crude petroleum and natural gas extraction.

211112 Natural gas liquid extraction.

Page 8 November 2014
4(b) Information Requested

(i) Data Items. EPA is finalizing the addition of 247 data elements, the deletion of 34

data elements, and the substantial revision of 13 data elements that are currently required to be 

reported under the rule. Table A-1 of Appendix A specifies each new data element that will be 

reported by industry segment. Table A-2 of Appendix A specifies each substantially revised data 

element that will be reported by industry segment. Table A-3 of Appendix A specifies each 

deleted data element by industry segment.

(ii) Respondent Activities. The owner or operator of a facility that is subject to the 

subpart W reporting requirements must report total annual GHG emissions. The primary tasks 

that reporting program respondents perform include:

1. Implementing and updating, as necessary, appropriate monitoring plans for each 

affected source and each affected unit at a source, as applicable; 

2. Conducting operation and maintenance activities associated with the monitoring, 

including quality assurance activities; 

3. Ensuring data quality, preparing annual reports of emission data, and submitting 

these reports to EPA; 

4. Potentially responding to questions or error messages from EPA; and 

5. Maintaining records for a minimum of three years.

Respondents that use CEMS also conduct tests to certify the operations of monitors, 

submit the results of these tests, and record emission data (this activity generally is performed 

electronically).

Reports must present the annual mass GHG emissions from each subpart W industry 

segment separately. EPA is revising the units of emissions reported in 40 CFR 98.236 to require 

reporting in metric tons of methane (CH4), CO2, and nitrous oxide (N2O), as applicable, instead 

of reporting each gas in metric tons of CO2e. EPA is also revising certain calculation methods 

that require the calculation of emissions in CO2e. The calculations used to determine GHG 

emissions, the frequency at which those calculations are required, and the methods used to 

estimate missing data depend on the specific subpart W industry segment.

(iii) Electronic Reporting. Respondents report all data electronically through the 

Electronic Greenhouse Gas Reporting Tool (e-GGRT). All new and revised data elements will be 

reported in the same way. As the e-GGRT accounts are already established, the only burden 

related to electronic reporting will be entering the data elements.

Page 9 November 2014
5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION 

METHODS, AND INFORMATION MANAGEMENT

5(a) Agency Activities

EPA Headquarters activities include the monitoring and verification of emission reports, 

database and software maintenance, communication and outreach, and program evaluation.

This ICR reflects an incremental agency burden for program operation activities, which 

include monitoring and verification of emission reports. Specifically, the additional burden for 

the review of new and revised data elements was estimated. 

5(b) Collection Methodology and Management

To collect data currently reported under the GHGRP, EPA previously established a 

central repository of inventory data for all respondents called the Electronic Greenhouse Gas 

Reporting Tool (e-GGRT). Respondents report data electronically, and EPA stores the data in the 

database. The e-GGRT system provides a user interface for entering the GHG data and also has

an XML reporting schema that allows facilities to upload GHG data directly. Under the revisions 

to Part 98, facilities subject to subpart W listed in section 4(a) will report the new data elements

and revised data elements via e-GGRT. 

The e-GGRT system follows Agency standards for design, security, data element and 

reporting format conformance, and accessibility. EPA designed the system in an attempt to 

minimize respondents’ burden by integrating the new reporting requirements with existing data 

collection and data management systems, when feasible. 

5(c) Small Entity Flexibility

This information collection will not have a significant economic impact on a substantial 

number of small entities. Nonetheless, EPA has tried to reduce the impact of this information 

collection on small entities. As part of the process of finalization of the final 2010 subpart W rule

(75 FR 74458, November 30, 2010), the EPA determined appropriate thresholds that reduced the 

number of small businesses reporting and conducted several meetings with industry associations 

to discuss regulatory options and the corresponding burden on industry, such as recordkeeping 

and reporting. The EPA continues to conduct significant outreach on the GHG reporting rule and 

maintains an “open door” policy for stakeholders to help inform the EPA’s understanding of key 

issues for the industries.

5(d) Collection Schedule

All data elements under this information collection will be submitted on an annual basis 

as part of the respondent’s annual report required under Part 98. 

Page 10 November 2014
6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

This section presents EPA’s estimates of the burden and costs to respondents associated 

with the activities described in section 4 as well as the federal burden hours and costs associated 

with the activities described in section 5(a). Section 6(a) provides estimates of burden (hours) for 

all respondent types. Section 6(b) contains estimates of respondent costs for the information 

collection. Section 6(c) summarizes federal burden and costs. Section 6(d) describes the 

respondent universe and the total burden and cost of this collection to respondents. Section 6(e) 

presents the bottom line burden and cost. Section 6(f) provides reasons for any change in burden. 

The burden statement for this information collection is in section 6(g). 

6(a) Estimating Respondent Burden

Respondent burden estimates are presented in Exhibit 6.1. EPA estimates that the total 

annual burden to all affected entities is approximately 244,000 hours per year over the three 

years covered by this information collection. Exhibit 6.1 presents aggregate burden and burden 

by subpart W industry segment. For details of the burden calculations, please see Appendix B.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs. Labor costs to respondents associated with this information 

collection include the amount of labor for facility staff to gather data, conduct analyses and 

calculations, and report the results. 

To calculate labor costs, EPA estimated Bureau of Labor Statistics using an approach 

consistent with the ICRs associated with the GHGRP currently approved by OMB.

1 For all 

subpart W industry segments the labor rates are: $121.72 for senior managers, $106.89 for 

middle managers, $78.29 for engineers, and $66.57 for technicians. 

EPA estimates that the total annual cost to all affected non-federal entities is $22.0

million over the three years covered by this information collection. Exhibit 6.1 presents

aggregate costs and costs by subpart W industry segment. For details of EPA’s cost calculations, 

please see Appendix C. The information collection will result in an overall increase in annual 

burden of approximately 7,700 hours and $603,000. This increase is split between the eight 

subpart W industry segments as shown in Exhibit 6.2.

(ii) Estimating Annualized Capital Costs and Operations and Maintenance (O&M) Costs. 

The amendments to subpart W that are included in this information collection affect only the 

labor costs. Capital and O&M costs have not changed from ICR Number 2300.12.

1 May 2011 National Industry-Specific Occupational Employment and Wage Estimates 

(http://www.bls.gov/oes/current/oessrci.htm) and Employer Costs for Employee Compensation for June of 2011 

(http://www.bls.gov/news.release/archives/ecec_09082011.pdf).

Page 11 November 2014

 
Exhibit 6.1 Annual Average Respondent Burden and Cost for Subpart W of the GHGRP

Subpart W

Industry Segment

No. 

Respondents

Responses/

Respondent

Total Responses 

(1)

Burden -

Technical 

(hrs)

Burden -

Managerial 

(hrs)

Total 

Burden 

(hrs)

Total Labor 

Cost

($)

Capital 

Cost

($)

O&M Cost

($)

Total Cost

($)

Onshore Petroleum and 

Natural Gas Production 1,033 2 2,066 81,115 20,809 101,924 $8,600,681 $59,206 $0 $8,659,886

Offshore Petroleum and 

Natural Gas Production

72 2 130 2,153 1,074 3,227 $285,779 $0 $0 $285,779

Onshore Natural Gas 

Processing

291 2 398 22,792 3,287 26,078 $2,035,807 $232,860 $124,257 $2,392,924

Onshore Natural Gas 

Transmission 

Compression

1,152 2 1,501 70,843 7,128 77,971 $5,943,128 $397,539 $1,161,170 $7,501,838

Underground Natural 

Gas Storage

139 2 224 10,590 2,107 12,697 $1,003,059 $65,803 $115,189 $1,184,051

Natural Gas Distribution 159 1 159 17,862 1,247 19,109 $1,390,860 $23,267 $254,082 $1,668,209

LNG Import and Export 

Equipment

4 1 4 331 43 373 $29,496 $2,400 $7,823 $39,718

LNG Storage 35 2 70 2,379 649 3,029 $250,085 $14,883 $27,434 $292,401

TOTAL 2,885 Varies 4,552 208,066 36,344 244,410 $19,538,894 $795,957 $1,689,954 $22,024,805

(1) Total responses equal the number of responses due to reporting of process emissions plus the number of responses due to reporting combustion emissions. The total responses do not equal the number 

of respondents multiplied by the number of responses per respondent because process emissions and combustion emissions are not applicable to the same number of respondents. See Appendix C for the 

number of respondents applicable to each by industry segment

.

Page 12 November 2014
Exhibit 6.2 Annual Average Change in Respondent Burden and Cost for Subpart W of the GHGRP

Subpart W Industry Segment

Change In Change In Change In Change In 

Total Burden Burden Total Cost Cost

(Technical Labor 

Hours)

(Technical Labor Hours / 

Respondent) ($)

($ / 

Respondent)

Onshore Petroleum and Natural Gas Production 1 4,171 4.04 $325,678 $315

Offshore Petroleum and Natural Gas Production 2 7 0.10 $564 $8

Onshore Natural Gas Processing 3 584 2.01 $46,766 $161

Onshore Natural Gas Transmission Compression 4 2,465 2.14 $194,183 $169

Underground Natural Gas Storage 5 248 1.78 $19,597 $141

Natural Gas Distribution 6 122 0.77 $9,585 $60

LNG Import and Export Equipment 7 6 1.57 $502 $125

LNG Storage 8 74 2.12 $6,603 $189

TOTAL 7,677 --- $603,478 --- 1 For Onshore Petroleum and Natural Gas Production, the technical labor hour burden increased from 97,754 hours to 101,924 hours, which increased the total cost from $8,334,208 

to $8,659,886. 2 For Offshore Petroleum and Natural Gas Production, the technical labor hour burden increased from 3,220 hours to 3,227 hours, which increased the total cost from $285,215 to 

$285,779.

3 For Onshore Natural Gas Processing, the technical labor hour burden increased from 25,495 hours to 26,078 hours, which increased the total cost from $2,346,157 to $2,392,924. 4 For Onshore Natural Gas Transmission Compression, the technical labor hour burden increased from 75,506 hours to 77,971 hours, which increased the total cost from $7,307,654 

to $7,501,838. 5 For Underground Natural Gas Storage, the technical labor hour burden increased from 12,450 hours to 12,697 hours, which increased the total cost from $1,164,454 to $1,184,051. 6 For Natural Gas Distribution, the technical labor hour burden increased from 18,986 hours to 19,109 hours, which increased the total cost from $1,658,624 to $1,668,209. 7 For LNG Import and Export Equipment, the technical labor hour burden increased from 367 hours to 373 hours, which increased the total cost from $39,217 to $39,718. 8 For LNG Storage, the technical labor hour burden increased from 2,954 hours to 3,029 hours, which increased the total cost from $285,799 to $292,401.

Page 13 November 2014
6(c) Estimating Agency Burden and Cost

This section describes the burden and cost to the federal government associated with this 

information collection. Federal activities under this information collection include EPA 

Headquarters oversight of the reporting program.

(i) EPA burden and cost. EPA activities associated with the mandatory GHG reporting 

rule include Headquarters oversight and implementation of the reporting program, e.g., 

monitoring and verification of emission reports, database and software maintenance,

communication and outreach, and program evaluation. EPA estimates that, in implementing 

subpart W, Headquarters will incur a burden of 4 full time equivalents (FTEs), or approximately 

$436,000 for these activities per year. There are no incremental burden increases due to these 

revisions to subpart W.

To develop EPA labor costs, EPA estimates the average hourly labor rate for salary and 

overhead and benefits for Agency staff to be $52.37. To derive this figure, EPA multiplied the 

hourly compensation at GS-12, Step 5 on the 2011 GS pay scale ($32.73) by the standard 

government benefits multiplication factor of 1.6 to account for overhead and benefits.

(ii) Burden and cost for federal facilities covered by the rule. Exhibit 6.3 presents the 

annual burden and cost for federal facilities that must comply with the rule.

Exhibit 6.3 Annual Agency Burden and Cost

Information Collection 

Activity

Annual 

Responses

Total 

Annual 

Burden

Hours

Labor Cost Non-Labor 

Cost

Total 

Annual 

Cost

W. Petroleum and Natural Gas 

Systems 1 8,320 $435,718 $0 $435,718

TOTAL 1 8,320 $435,718 $0 $435,718

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

The number of respondents in each subpart W industry sector that will perform the 

required activities under this information collection is presented in Exhibit 6.1.

6(e) Bottom Line Burden Hours and Costs

The bottom line burden hours and costs are shown in Exhibit 6.4.

Page 14 November 2014
Exhibit 6.4 Bottom Line Annual Burden and Cost 

Number of Respondents 2,885 From Exhibit 6.1

Total Annual Responses 4,552 From Exhibit 6.1

Number of Responses per 

Respondent 1.6 Total annual responses from above ÷ Total 

respondents from above

Total Respondent Hours 244,410 From Exhibit 6.1

Hours per Response 53.7 Total annual hours from above ÷ Total 

respondents from above

Annual O&M and Capital Cost ($) 2,485,912 From Exhibit 6.1

Total Respondent Cost ($) 22,024,805 From Exhibit 6.1

Total Hours 

(Respondents and Agency) 252,730 Total respondent hours from above + Total 

EPA hours

Total Cost 

(Respondents and Agency) ($) 22,460,524 Total respondent cost from above + Total 

EPA cost

Note: Detail may not add exactly to total due to independent rounding.

6(f) Reasons for Change in Burden

This rule will result in an overall increase in annual burden of approximately 7,700 hours 

and $603,000 (labor costs). Specific respondent activities that impose either a reduction or 

increase in burden and costs due to EPA’s revisions to subpart W are identified below and 

reviewed in more detail in Appendix B.

Reporting New Data Elements. For each of the 247 new data elements required to be 

reported (see section 4(b)(i) and Appendix A), respondents will be required to calculate the data 

element using readily available data, and submit the value via e-GGRT as part of the annual 

report currently required under Part 98. This revision is an increase to burden and cost.

Reporting Revised Data Elements. For each of the 13 revised data elements required to 

be reported (see section 4(b)(i)), respondents will be required to calculate the data element using 

readily available data, and submit the value via e-GGRT as part of the annual report currently 

required under Part 98. This revision is an increase to burden and cost.

Deleted Data Elements. EPA is deleting 34 data elements that are currently required to 

be reported (see section 4(b)(i)), respondents will no longer be required to calculate the data 

element and submit the value via e-GGRT as part of the annual report currently required under 

Part 98. This revision is a reduction to burden and cost.

Page 15 November 2014
Gas Well Completions And Workovers. EPA is revising reporting requirements for 

completions and workovers to differentiate between completions and workovers with different 

well type combinations in each sub-basin category. EPA is clarifying the number of 

measurements or calculations that must be taken to estimate the average ratio of flowback rate 

(FRM). Respondents may have to conduct more tests/measurements because a separate FRM 

value is required for each well type combination. This revision is an increase to burden and cost.

Gas Well Venting During Completions Or Workovers From Hydraulic Fracturing 

Calculation. EPA is modifying Equation W-10A (which is a calculation that determines annual 

volumetric total gas emissions from gas well venting during completions or workovers following 

hydraulic fracturing) in order to enable quantification of natural gas emitted during the initial 

flowback stage of a well when insufficient gas is present to enable separation and metering. In 

addition, the EPA is modifying Equation W-10A to ensure respondents only account for sales 

gas volume once in this calculation. The method is similar in complexity as the previous method 

and uses measurements that are of similar complexity. Therefore, this change will not impose 

any additional (or reduced) burden and costs.

Gas Well Venting During Completions Or Workovers Without Hydraulic Fracturing 

Calculation. EPA is revising Equation W-13 (which is a calculation that determines annual 

volumetric total gas emissions from gas well venting during completions or workovers without 

hydraulic fracturing) to separate the calculation of emissions from workovers from the 

calculation of completions into two equations. Respondents will have to perform two 

calculations as opposed to one; however, it is the same calculation that respondents are currently 

doing only being broken into two steps. This change will not impose any additional (or reduced) 

burden and costs.

Flare Stack Emissions Calculation. EPA is revising the calculation and reporting 

requirements for onshore natural gas transmission compression, underground natural gas storage, 

LNG storage, and LNG import and export to include emissions from flare stacks. Facilities that 

had flares formerly did not have to report flare stack emissions, but will now need to collect flare 

data, calculate, and report these emissions. This revision is an increase to burden and cost.

Monitoring Group Of Manifolded Compressor Sources. EPA is revising the monitoring 

requirements so that, in cases where multiple compressor sources are manifolded together 

downstream, respondents can measure downstream of the manifold and will not have to measure 

the compressor sources individually. For manifolded compressors, reporters will also have to 

report activity data for the manifold (e.g., number of compressor sources manifolded together

and mode of each compressor). Respondents are no longer required to annually measure 

compressor sources that are manifolded individually. Instead, respondents will measure the 

Page 16 November 2014
manifolded group of compressor sources once per year. Therefore, this change is a burden 

reduction for respondents that have two or more compressor sources manifolded together.

Calculation For Compressor Sources Vented To Flare. EPA is removing vented 

compressor emissions that go to a flare from the compressor emissions total (clarifying that these 

emissions should be reported in the flared emissions total) and retain the requirement to report 

uncontrolled vented emissions from compressors. Respondents are no longer required to perform 

individual compressor leak measurements or continuous measurements, but rather perform a 

single calculation under the flare stack emissions methodology. The latter is less burdensome 

because it only requires respondents to either continuously monitor total flow and composition to 

the flare, or use engineering estimates.

Triennial Testing Of Compressors. EPA is finalizing that compressors not measured in 

the “not-operating-depressurized-mode” for over three years, must be measured in the “notoperating-depressurized-mode” at the next scheduled depressurized shutdown (for centrifugal 

compressors) or at the next scheduled shutdown when the compressor rod packing is replaced 

(for reciprocating compressors). Even though the “not-operating-depressurized-mode” is only 

measured at scheduled shutdowns (which might be every three years or greater), the reporter is 

still required to conduct an annual measurement in whatever mode the compressor is found. 

Therefore, the frequency in measurements is unchanged, and will not impose any additional (or 

reduced) burden and costs.

Pneumatic Devices Calculation. EPA is simplifying the procedure for determining the 

counts of pneumatic devices operating each year. For the onshore petroleum and natural gas 

production industry segment, reporters continue to have the option in the first two reporting 

years to estimate counts of pneumatic devices using engineering estimates. This change will not 

impose any additional (or reduced) burden and costs.

Liquids Unloading Calculation. EPA is modifying the liquids unloading calculation to 

The EPA is modifying the liquids unloading calculation to annualize venting data for facilities 

that use Calculation Method 1. The EPA is also revising Calculation Method 1 at 40 CFR 

98.233(f)(1) to separate the calculation and reporting of emissions from wells that have plunger 

lifts and wells that do not have plunger lifts. The impacts assessment assumed that Calculation 

Method 2 and Calculation Method 3 are lower-burden options than Calculation Method 1 and 

that reporters will choose the lower-burden option. While the changes to Calculation Method 1 

will increase facility flexibility, no changes were made to Calculation Method 2 or Calculation 

Method 3. Therefore, these changes will not impose any additional (or reduced) burden and 

costs.

Page 17 November 2014
Blowdown Vent Stacks Calculation By Equipment. EPA is revising the calculation for 

“unique physical volume” so respondents can report emissions from blowdown vent stacks by 

equipment instead of by "unique physical volume." Although respondents are no longer required 

to report blowdown vent stack emissions by each "unique physical volume," respondents still 

have to calculate blowdown vent stack emissions from each "unique physical volume.” 

Therefore, this change will not impose any additional (or reduced) burden and costs.

Blowdown Vent Stacks Calculation Compressibility Term. EPA is allowing the optional 

use of a compressibility factor in Equations W-14A, W-14B, W-33 and W-34. As at proposal, 

the use of a default value is assumed to be the option with the lowest reporter burden and this 

change will not impose any additional (or reduced) burden and costs.

Blowdown Vent Stacks Direct Measurement. EPA is allowing an option to directly 

measure blowdown emissions in lieu of performing "unique physical volume" calculations. 

Although this option may decrease burden for those reporters that currently measure blowdown 

emissions, because they could simply report these measured emissions (without the burden of 

performing calculations), the EPA conservatively assumed that facilities would not directly 

measure all of their "unique physical volumes” and therefore the EPA estimated that this change 

would not impose any additional (or reduced) burden and costs. The EPA is also adding an 

optional calculation method (40 CFR 98.233(i)(3)) for blowdown emissions for situations where 

a flow meter is in place and including associated reporting requirements in 40 CFR 98.236. As 

this is an optional calculation, this change will not impose any additional (or reduced) burden 

and costs.

Associated Gas Venting And Flaring Calculation. EPA is modifying the calculation 

method for associated gas venting and flaring to account for situations where part of the gas is 

going to the sales line. The calculation method modifies the current equation to include a new 

term for the volume of sales gas, which is already being calculated elsewhere and/or can be 

estimated. Therefore, this change will not impose any additional (or reduced) burden and costs.

The EPA is not finalizing the addition of the proposed term “EREp,q” for emissions 

reported under other sources. This change will not impose any additional (or reduced) burden 

and costs.

Above Grade Metering-Regulating Stations Calculation. EPA is finalizing technical 

revisions to the natural gas distribution segment to clarify the calculation methodologies and 

reporting requirements for above grade metering-regulating stations. The rule clarifies that 

respondents only calculate two emission factors (one for CO2 and one for CH4) for 

meter/regulator runs instead of separate emission factors for all component types. These changes 

will not impose any additional (or reduced) burden and costs.

Page 18 November 2014
BAMM. As a change from proposal, the EPA is revising 40 CFR 98.234(f) to provide 

short-term transitional BAMM. BAMM was designed to be a temporary flexibility mechanism 

and not a permanent option in the rule. Reporters have the option of using BAMM from January 

1, 2015 to March 31, 2015 without prior EPA approval for certain parameters that cannot 

reasonably be measured according to the monitoring and QA/QC requirements of 40 CFR 

98.234. Reporters also have the opportunity to request an extension for the use of BAMM from 

April 1, 2015 through December 31, 2015. Because BAMM is optional, changes to transitional 

BAMM do not change the burden associated with the methods of subpart W.

6(g) Burden Statement

The respondent reporting burden for this collection of information is estimated to 

average 244,410 hours per year for a three year period, where identical annual costs are 

anticipated for all three years. The average annual burden to EPA for this period is estimated to 

be 8,320 hours for oversight activities. The annual public reporting and recordkeeping burden for 

this collection of information is estimated to average 53.7 hours per response.

Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a federal agency. This 

includes the time needed to review instructions; develop, acquire, install, and utilize technology 

and systems for the purposes of collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to respond 

to a collection of information; search data sources; complete and review the collection of 

information; and transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB control number. The OMB 

control numbers for EPA’s regulations are listed in 40 CFR Part 9.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OAR-2011-0512, which is available for online viewing at 

http://www.regulations.gov, or in person viewing at the Air and Radiation docket in the EPA 

Docket Center (EPA/DC), William Jefferson Clinton Federal Building - West, Room 3334, 1301 

Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is 

open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The 

telephone number for the Reading Room is (202) 566-1744, and the telephone number for the 

Air and Radiation docket is (202) 566-1742. An electronic version of the public docket is 

available at http://www.regulations.gov. This site can be used to submit or view public 

comments, access the index listing of the contents of the public docket, and to access those 

documents in the public docket that are available electronically. When in the system, select 

Page 19 November 2014
“search,” then key in the Docket ID Number identified above. Also, you can send comments to 

the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th 

Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA 

Docket ID Number EPA-HQ-OAR-2011-0512 and OMB Control Number 2060-0629 on any 

correspondence.

PART B of the Supporting Statement

This section is not applicable because statistical methods are not used in data collection 

associated with the final amendments.

Page 20 November 2014