Page 1 February 2014 

SUPPORTING STATEMENT 

ENVIRONMENTAL PROTECTION AGENCY 

Information Collection Request for the Greenhouse Gas Reporting Program (Greenhouse 

Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural 

Gas Systems; Proposed Rule) 

1. IDENTIFICATION OF THE INFORMATION COLLECTION 

1(a) Title of the Information Collection 

Greenhouse Gas Reporting Program (Greenhouse Gas Reporting Rule: Revisions and 

Confidentiality Determinations for Petroleum and Natural Gas Systems; Proposed Rule); OMB 

control number 2060-0629; ICR number 2300.15. 

1(b) Short Characterization/Abstract 

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 would be imposed by “Greenhouse Gas Reporting Rule: Revisions and 

Confidentiality Determinations for Petroleum and Natural Gas Systems; Proposed Rule” 

(hereafter referred to as the “proposed revisions”). 

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). 

EPA is proposing to clarify certain terms and definitions, and correct certain technical 

and editorial errors that have been identified during the course of implementation; these 

proposed revisions are not expected to substantively affect respondent burden. EPA is also 

proposing to revise certain calculation methods, and amend certain monitoring and data reporting 
 Page 2 February 2014 

requirements; some of these proposed revisions may affect respondent burden. See Section 4(b) 

and Appendix A for a complete list of proposed revisions to the reporting requirements. 

Compared with the estimated respondent burden identified in the information collection 

for the Greenhouse Gas Reporting Program (GHGRP) currently approved by Office of 

Management and Budget (OMB), this proposed information collection will result in an overall 

increase in annual burden of 6,920 hours and $543,000 (labor costs), as shown in Section 6. 

2. NEED FOR AND USE OF THE COLLECTION 

2(a) Need/Authority for the Collection 

The EPA is proposing this information collection under its existing Clean Air Act (CAA) 

authority provided in CAA section 114. As stated in the October 30, 2009 preamble to Part 98 

(74 FR 56260), CAA section 114(a)(1) provides EPA broad authority to require the information 

proposed to be gathered by Part 98 because such data would inform and are relevant to EPA’s 

carrying out a wide variety of CAA provisions. Additionally, signed into law on December 26, 

2007, the FY2008 Consolidated Appropriations Act 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.” 

Sections 114 and 208 of the CAA provide EPA authority to require the information 

mandated by the GHGRP because such data will inform and are relevant to future policy 

decisions. 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. For these reasons, the Administrator 

may request that a person, on a one-time, periodic or continuous basis, establish and maintain 

records, make reports, and, among other things, provide such information the Administrator may 

reasonably require. Because EPA does not yet know the specific policies that will be adopted, 

the data reported under the GHGRP is of sufficient quality to inform policy and program 

development. 
 Page 3 February 2014 

2(b) Practical Utility/Users of the Data 

The GHGRP information collection 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 now easily accessible to the public at: http://ghgdata.epa.gov/ghgp/main.do. Reporting 

entities 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 can help EPA transition to use of the 2006 

Intergovernmental Panel on Climate Change (IPCC) Guidelines for National Greenhouse Gas 

Inventories. This data resource also 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. 

The facility-specific GHG emissions 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. 

Subpart W data can be used to inform a number of different types of analyses. For 

example, it can complement atmospheric GHG studies and inform updates to emission 

inventories. Numerous activity data are collected that can be used to improve understanding of 

the occurrence of emissions from a variety of sources. The GHGRP is not intended to be a 

survey and the respondents affected by the program are not intended to be a statistical sample of 

a larger universe of entities. 
 Page 4 February 2014 

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA 

3(a) Nonduplication 

The new information proposed to be collected under the proposed revisions are 245 new 

data elements and 15 substantially revised data elements (refer to section 4(b) and Appendix A 

for a list of these data elements). These proposed new and substantially revised data elements 

consist primarily of quantities that provide information on the activity level at the facility, 

emission factors used, characteristics of carbon-containing streams, and other process 

information that would 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 proposed new and substantially revised reporting elements, described 

above, are the same types of industry data currently collected under the GHGRP. EPA previously 

evaluated these types of industry data currently collected under Part 98, and concluded that they 

do not duplicate other information collections, as described below. This conclusion, as described 

below, applies to the proposed new and substantially revised data elements as well. 

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 
 Page 5 February 2014 

 IPCC Guidelines for National Greenhouse Gas Inventories. 

These programs led the way in reporting of GHG emissions before the federal 

government acted and assisted in quantifying the GHG reductions achieved by various policies. 

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

proposal. 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 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-2008-0508-056. For further discussion on the relationship of the 

GHGRP to other programs, please refer to the preambles of each of the GHGRP rulemakings 

(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-HQ-OAR-2008-

0508-0054). Some GHG programs are described below: 

 A number of EPA’s voluntary partnership programs include a GHG emissions and/or 

reductions reporting component (e.g., Natural Gas STAR program, etc.). However, 

the GHGRP has much broader coverage than the voluntary programs and therefore 

helps EPA learn more about emissions from facilities not included in current 

programs. 

 EPA reviewed the Inventory, which is an annual comprehensive top-down assessment 

of national greenhouses gas emissions. While the Inventory is generally compiled 

from national surveys (i.e., not broken down at the geographic or facility level), the 

GHGRP focuses on bottom-up data from individual facilities that exceed appropriate 

thresholds. The bottom-up approach to data collection in the GHGRP can help reduce 

uncertainty in emissions estimates for specific industries, and more broadly, helps 
 Page 6 February 2014 

EPA transition to use of the 2006 IPCC Guidelines for National Greenhouse Gas 

Inventories, which will be required to meet international reporting obligations under 

the United Nations Framework Convention on Climate Change in the near future. 

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: Revisions and Confidentiality Determinations for Petroleum 

and Natural Gas Systems; Proposed 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: 

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

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

planning organizations; 

 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. 
 Page 7 February 2014 

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. Subpart W received comments 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 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 proposing to make certain revisions to the petroleum and 

natural gas systems source category GHG reporting requirements. The proposed changes revise 

certain calculation methods, amend certain monitoring and data reporting requirements, clarify 

certain terms and definitions, and correct certain technical and editorial errors identified during 

the course of implementation. The proposed 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 proposing 

confidentiality determinations for the new and substantially revised data elements contained in 

these proposed amendments; we are also proposing a revised 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 proposed revisions to Part 98. 

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

authorized by the CAA, and use the data for the purposes described in section 2(b). If the 
 Page 8 February 2014 

information collection were not carried out on this schedule, the Agency would not be able to 

develop an informed tracking system of trends in GHG emissions across the country. 

3(e) General Guidelines 

This collection of information is consistent with all OMB guidelines under 5 CFR 

1320.6. 

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 would not result 

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

FR 39094). 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. In the current action, the EPA is proposing confidentiality 

determinations for the new and substantially revised data elements contained in these proposed 

amendments; we are also proposing a revised confidentiality determination for one existing data 

element. 

3(g) Sensitive Questions 

The revisions to reporting or recordkeeping requirements in the proposed revisions to 

Part 98 do not include sensitive questions. 

4. THE RESPONDENTS AND THE INFORMATION REQUESTED 
 Page 9 February 2014 

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 proposed revisions to Part 98 affect facilities subject to the 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. 

4(b) Information Requested 

(i) Data Items. EPA is proposing that 245 new data elements be reported. EPA is also 

proposing to delete 63 data elements and substantial revise15 data elements that are currently 

required to be reported under the rule. Table 1 of Appendix A specifies each new data element 

that would be reported by industry segment. Table 2 of Appendix A specifies each substantially 

revised data element that would be reported by industry segment. Table 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 Part 

98, subpart W’s reporting requirements must report total annual GHG emissions. The primary 

tasks that reporting program respondents perform include: 

1. Implement and update, as necessary, appropriate monitoring plans for each 

affected source and each affected unit at a source, as applicable; 
 Page 10 February 2014 

2. Operation and maintenance activities associated with the monitoring, including 

quality assurance activities; 

3. Ensuring data quality, preparing annual reports of emissions 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 emissions data (this activity generally is performed 

electronically). 

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

segment separately. EPA is proposing to revise 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 proposing to revise 

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, the 

methods used to estimate missing data, and the QA/QC requirements depend on the specific 

subpart W industry segment. 

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 
 Page 11 February 2014 

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

database. The e-GGRT system has an XML reporting schema that allows facilities to upload 

GHG data directly in lieu of using the web forms provided through e-GGRT. Under the proposed 

revisions to Part 98, facilities subject to subpart W listed in section 4(a) would report the 

proposed 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 subpart W rule, the 

EPA took several steps to evaluate the effect of the rule on small entities. For example, the EPA 

determined appropriate thresholds that reduced the number of small businesses reporting. In 

addition, the EPA conducted several meetings with industry associations to discuss regulatory 

options and the corresponding burden on industry, such as recordkeeping and reporting. Finally, 

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 would be submitted on an annual 

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

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 
 Page 12 February 2014 

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 243,652 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 

Costs to respondents associated with this information collection include labor costs (i.e., 

the cost of labor by facility staff to meet the rule’s information collection requirements). 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 industry 

segments the labor rates are: $121.72 for senior managers, $106.89 for middle managers, $78.29 

for engineers, $66.57 for technicians. 

EPA estimates that the total annual cost to all affected non-federal entities is $22.1 

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 proposed information collection will result in an overall increase in 

annual burden of 6,920 hours and $543,000. This increase is split between the eight subpart W 

industry segments as shown in Exhibit 6.2. 

 

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 13 February 2014 

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

Subpart

W

Industry Segment

No.

Respond‐

ents

Responses/

Respondent

Total

Responses

(1)

Burden ‐ 

Technical

(hrs)

Burden ‐ 

Managerial

(hrs)

Burden ‐ 

Clerical

(hrs)

Burden

‐ Legal

(hrs)

Total

Burden

(hrs)

Total Labor

Cost

($K)

Capital

Cost

($K)

Onshore Natural Gas

Processing

291 2 398 22,625 3,287 0 0 25,912 $2,023 $233 

Onshore Natural Gas

TransmissionCompression

1,152 2 1,501 70,599 7,128 0 0 77,727 $5,924 $398 

Underground Natural

Gas Storage

139 2 224 10,539 2,107 0 0 12,646 $999 $66 

LNG Import and Export

Equipment 4 2 4 326 43 0 0 368 $29 $2 

Onshore Petroleum and

Natural Gas Production 1,033 2 2,066 81,006 20,809 0 0 101,816 $8,592 $59 

Natural GasDistribution

159 2 159 17,732 1,247 0 0 18,979 $1,381 $23 

LNG Storage

35 2 68 2,347 626 0 0 2,973 $245 $15 

Offshore Petroleumand Natural GasProduction

72 2 130 2,157 1,074 0 0 3,231 $286 $0 

TOTAL

2,885 Varies 4,550 207,332 36,320 0 0 243,652 $19,478 $796 

 (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 re

of respondents multiplied by the number of responses per respondent because process emissions and combustion emissions are not applicable to the same number of respnumber of respondents applicable to each by industry segment. 
 Page 14 February 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 

Total Burden Burden Total Cost 

(Technical Labor 

Hours) 

(Technical Labor 

Hours / Respondent) ($) 

Onshore Natural Gas Processing 1 417 1.43 $33,612 Onshore Natural Gas Transmission Compression 2 2,221 1.93 $174,662 Underground Natural Gas Storage 3 197 1.42 $15,552 LNG Import and Export Equipment 4 1 0.33 $125 Onshore Petroleum and Natural Gas Production 5 4,062 3.93 $317,186 Natural Gas Distribution 6 -8 -0.05 -$622 LNG Storage 7 18 0.52 $1,507 Offshore Petroleum and Natural Gas Production 8 11 0.15 $846 TOTAL 6,920 --- $542,868 1 For onshore natural gas processing, the technical labor hour burden increased from 25,495 hours to 25,912 hours, which increased the total cost from 2 For onshore natural gas transmission compression, the technical labor hour burden increased from 75,506 hours to 77,727 hours, which increased th

to $7,482,000. 

3 For underground natural gas storage, the technical labor hour burden increased from 12,450 hours to 12,646 hours, which increased the total cost fro4 For LNG import and export equipment, the technical labor hour burden increased from 367 hours to 368 hours, which increased the total cost from 5 For onshore petroleum and natural gas production, the technical labor hour burden increased from 97,754 hours to 101,816 hours, which increased t

to $8,651,000. 

6 For natural gas distribution, the technical labor hour burden increased from 18,986 hours to 18,979 hours, which increased the total cost from $1,657 For liquefied natural gas (LNG) storage, the technical labor hour burden increased from 2,954 hours to 2,973 hours, which increased the total cost f8 For offshore petroleum and natural gas production, the technical labor hour burden increased from 3,220 hours to 3,231 hours, which increased the 

$286,000
 Page 15 January 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. 

 

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 an 

incremental burden of 4 full time equivalents (FTEs), or just $436,000 for these activities. 

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. 

In addition to the labor cost, EPA will incur an incremental cost of just under $800 

thousand in each of the first three years for third-party verification. 

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 ($K) 

Information Collection 

Activity 

Annual 

Responses 

Total 

Annual 

Burden 

Hours 

Labor Cost 

($K) 

Non-Labor 

Cost 

($K) 

Total 

Annual 

Cost 

($K) 

W. Petroleum and Natural Gas 

Systems 1 8320 $436 $783 $1,200 

TOTAL 1 8320 $436 $783 $1,200 
 Page 16 January 2014 

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. 

Exhibit 6.4 Bottom Line Annual Burden and Cost 

Number of Respondents 2,885 From Exhibit 6.1 

Total Annual Responses 4,550 From Exhibit 6.1 

Number of Responses per 

Respondent 1.6 

Total annual responses from above ÷ 

Total respondents from above 

Total Respondent Hours 243,652 From Exhibit 6.1 

Hours per Response 53.5 

Total annual hours from above ÷ 

Total respondents from above 

Annual O&M and Capital Cost 

($K) 2,486 From Exhibit 6.1 

Total Respondent Cost (labor + 

non) 

($K) 

21,964 From Exhibit 6.1 

Total Hours (Respondents and 

Agency) 29.3 

Total respondent hours from above ÷ 

Total EPA hours 

Total Cost (Respondents and 

Agency) ($K) 18.3 

Total respondent cost from above ÷ 

Total EPA hours 

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

6(f) Reasons for Change in Burden 

This proposed rule will result in an overall increase in annual burden of 6,920 hours and 

$543,000 (labor costs). Specific respondent activities that impose either a reduction or increase 
 Page 17 January 2014 

in burden and costs due to EPA’s proposed revisions to Part 98, subpart W are identified below 

and reviewed in more detail in Appendix B. 

Reporting Proposed New Data Elements. For each of the 245 new data elements required 

to be reported (see section 4(b)(i)), respondents would 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 proposed revision is an increase to burden and cost. 

Reporting Proposed Revised Data Elements. For each of the 15 revised data elements 

required to be reported (see section 4(b)(i)), respondents would 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 proposed revision is an increase to burden and cost. 

Deleted Data Elements. EPA is proposing to delete 63 data elements that are currently 

required to be reported (see section 4(b)(i)), respondents would 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 proposed revision is a reduction to burden and cost. 

Completions And Workovers. EPA is proposing to revise 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. This proposed revision is an increase to burden and cost. 

Flare Stack Emissions Calculation. EPA is proposing to revise 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 proposed revision is an increase 

to burden and cost. 

Monitoring Group Of Manifolded Compressor Sources. EPA is proposing to revise the 

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

together downstream, respondents can measure downstream of the manifold and would not have 

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

have to report activity data for the manifold (i.e. number of compressor sources manifolded 
 Page 18 January 2014 

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

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

manifolded group of compressor sources three times per year. Therefore, this proposed change is 

a burden reduction for respondents that have more than three compressor sources manifolded 

together. 

Calculation For Compressor Sources Vented To Flare. EPA is proposing to remove 

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 since it only requires respondents to either continuously monitor total flow and 

composition to the flare, or use engineering estimates. 

Other respondent activities that are associated with EPA’s proposed revisions to Part 98, 

subpart W and do not impose any additional (or reduced) burden and costs are discussed below. 

Site-Specific Composition Data For Pneumatic Devices Calculation. EPA is proposing to 

allow either the use of site-specific composition data for natural gas transmission compression 

and underground natural gas storage facilities or the use of a default gas composition. The 

calculation still must be conducted in much the same way that is currently required; however, 

respondents are now allowed to use site-specific data if it is available. 

Liquids Unloading Calculation. EPA is proposing to modify the liquids unloading 

calculation to allow flexibility for metered data that does not exactly correspond to a given 

reporting year (i.e. January 1st to December 31st). While this modification increases facility 

flexibility, the calculation still must be conducted in much the same way that is currently 

required. 

Gas Well Venting During Completions Or Workovers Following Hydraulic Fracturing 

Calculation. EPA is proposing to modify 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, as opposed to 

measurement, 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 proposing to modify 
 Page 19 January 2014 

Equation W-10A to ensure respondents only account for sales gas volume once in this 

calculation. The proposed method is similar in complexity as the previous method and uses 

measurements that are of similar complexity. 

Gas Well Venting During Completions Or Workovers Without Hydraulic Fracturing 

Calculation. EPA is proposing to revise 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. 

Blowdown Vent Stacks Calculation By Equipment. EPA is proposing to revise 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." 

Blowdown Vent Stacks Calculation Compressibility Term. EPA is proposing to add a 

compressibility term to the blowdown vent stack calculations. It is anticipated that respondents 

handle gas within the proposed compressibility factor default ranges; therefore, it is unlikely that 

adding this compressibility factor term into the blowdown vent stack calculations will increase 

burden to respondents. 

Blowdown Vent Stacks Direct Measurement. EPA is proposing to allow an option to 

directly measure blowdown emissions in lieu of performing "unique physical volume" 

calculations. Although this option may decrease burden for those respondents that currently do 

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

performing calculations), it is unlikely that facilities directly measure all of their "unique 

physical volumes.” 

Associated Gas Venting And Flaring Calculation. EPA is proposing to modify the 

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

the gas is going to the sales line and part of the gas emissions are reported under other emission 

sources included in this subpart (i.e., tank venting). The respondents still have to perform a 
 Page 20 January 2014 

similar calculation to what is currently being required. Although the proposed calculation 

method modifies the current equation to include two new terms, these new terms are already 

being calculated elsewhere and/or can be estimated. 

Triennial Testing Of Compressors. EPA is proposing 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. 

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

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

reporting requirements for above grade metering-regulating stations. EPA is clarifying 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. 

Missing Data Methods. Except for missing data that are continuously monitored or 

measured (for example flow meters), or for missing temperature or pressure data, a complete 

record of all estimated and/or measured parameters used in the GHG emissions calculations is 

required by the current rule. EPA is proposing certain ways that respondents can substitute a 

value for certain specific missing estimated and/or measured parameters. In addition, for 

respondents who are newly subject to subpart W in a given reporting year and for respondents 

who acquire wells during a reporting year that were not subject to subpart W prior to the 

acquisition, EPA is proposing to allow the use of best engineering estimates for any parameter 

that cannot be reasonably measured or obtained according to the requirements in subpart W for 

up to six months from the first date of subpart W applicability. 

BAMM. EPA is proposing to remove all provisions in 40 CFR 98.234(f) for BAMM. 

BAMM is designed to be a temporary flexibility mechanism and not a permanent option in the 

rule. Therefore, removing BAMM does not change the burden associated with the methods of 

Subpart W. 
 Page 21 January 2014 

6(g) Burden Statement 

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

average 243,652 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 53.5 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 

“search,” then key in the Docket ID Number identified above. Also, you can send comments to 
 Page 22 January 2014 

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.