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MEMORANDUM 

DATE: August 2013 

TO: Docket EPA-HQ-OAR-2010-0929 

FROM: Lisa Grogan-McCulloch, U.S. EPA 

SUBJECT: Assessment of Cost Impacts of 2015 Inputs Proposal – Revisions to Reporting, 

Recordkeeping, and Verification Requirements under the Greenhouse Gas 

Reporting Program 

1.0 INTRODUCTION 

Facilities subject to the GHG reporting rule (40 CFR part 98, hereafter referred to as “Part 98”) 

must report their GHG emissions to the EPA through the electronic Greenhouse Gas Reporting 

Tool (e-GGRT). The EPA is proposing revisions to the reporting and recordkeeping 

requirements in Part 98 that would apply to reporters subject to any of the 24 subparts listed in 

Table 1. The proposed revisions include: 

 Adding a requirement for certain reporters under 24 subparts to use an EPA-provided 

inputs verification tool. For these subparts, the designated inputs to emission equations 

for which reporting was deferred to 2015 (hereafter referred to as “’input to equations’ 

data elements”) and disclosure concerns have been identified would be entered into the 

tool.1

 The tool would calculate the emissions and perform electronic verification. The 

tool would not retain the entered inputs (i.e., the inputs would not be reported to the 

EPA); instead, the tool would conduct certain checks (e.g., accuracy of the inputs) at the 

time of data entry and generate a verification summary. The verification summary, which 

would be accessible to the EPA once the annual report is submitted, would provide the 

EPA with information to conduct further verification if necessary. 

 For reporters required to use the inputs verification tool, changing the required format for 

maintaining records of these inputs to emission equations. 

 For reporters required to use the inputs verification tool, lengthening the record retention 

period from 3 to 5 years for all records maintained under Part 98 (including subparts that 

do not require the use of the tool). 

 

1 Under this proposal, the inputs verification tool would not be required to be used by reporters for any reported GHG for 

which the reporter uses a CEMS or an EPA-approved alternative method (as allowed under sections 98.33(a)(5), 98.53(a)(2), and 

98.223(a)(2) of Part 98) to calculate the reported GHG value, rather than using "inputs to equations" data elements and the 

associated EPA-provided calculation methodologies to calculate the reported GHG value. 
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 For certain reporters required to use the inputs verification tool, adding new data 

elements to be reported for the EPA’s verification purposes, and proposing 

confidentiality determinations for the new data elements proposed to be reported. 

 For reporters required to use the inputs verification tool, removing the requirement to 

report the inputs to emission equations for which reporting was deferred to 2015 and 

disclosure concerns have been identified, and requiring these data to be kept as records. 

 Table 1. Subparts Affected by the Proposed Reporting, Recordkeeping, and Verification 

Requirements1

Subpart Source Category 

Number of “Inputs to Equations” Data Elements 

Currently Required to 

be Reported 

For which Reporting 

is Proposed to be 

Removed 

C General Stationary Fuel Combustion 

Sources except Certain Electric 

Generators2

263

 263

E Adipic Acid Production 21 11 

F Aluminum Production 29 29 

G Ammonia Manufacturing 8 8 

H Cement Production 16 14 

K Ferroalloy Production 13 13 

L Fluorinated Gas Production 55 46 

N Glass Production 3 2 

O HCFC-22 Production and HFC-23 

Destruction 15 12 

P Hydrogen Production 7 7 

Q Iron and Steel Production 93 92 

R Lead Production 10 10 

S Lime Manufacturing (non-CEMS) 9 9 

U Miscellaneous Uses of Carbonate 6 6 

V Nitric Acid Production 21 6 

X Petrochemical Production 21 21 

Y Petroleum Refineries 80 75 

Z Phosphoric Acid Production 4 4 

AA Pulp and Paper Manufacturing 31 28 

BB Silicon Carbide Production 3 3 

CC Soda Ash Manufacturing 10 4 

EE Titanium Dioxide Production 2 2 

GG Zinc Production 8 8 

TT Industrial Waste Landfills 3 3 
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 Table 1. Subparts Affected by the Proposed Reporting, Recordkeeping, and Verification 

Requirements1

Subpart Source Category 

Number of “Inputs to Equations” Data Elements 

Currently Required to 

be Reported 

For which Reporting 

is Proposed to be 

Removed 1

 The EPA is also proposing to revise the general recordkeeping requirements in subpart A of Part 98, which would affect the 

recordkeeping duration for all records maintained under Part 98 by reporters subject to these subparts. 2

 The reporting requirements applicable to certain stationary fuel combustion sources (e.g., individual units, aggregations of 

units, common pipes, or common stacks) subject to 40 CFR part 98, subpart C remain the same under the proposed 

amendment. Subpart C would continue to require reporting of all applicable “inputs to equations” data elements for 

stationary fuel combustion sources that meet both of the following criteria: (1) the stationary fuel combustion source contains

at least one combustion unit connected to a fuel-fired electric generator that has been granted access by the Public Utilities 

Commission to deliver power to the local or regional electric power grid (excluding generators connected to combustion 

units that are subject to 40 CFR part 98, subpart D); and (2) the stationary fuel combustion source is located at a facility for 

which the sum of the combined nameplate capacities for all such electric generators is greater than or equal to 1 megawatt 

electric output. Subpart C reporters would not report “inputs to equations” data elements for all other types of stationary fuel 

combustion sources subject to subpart C. 

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 Includes one “inputs to equations” data element, 40 CFR 98.3(d)(3)(v), which is specified in subpart A of Part 98 and 

applies to only certain reporters under subpart C of part 98.Under this evaluation of the subpart C “inputs to equations” data 

elements, this one subpart A “input to equation” data element is grouped together with the 25 “inputs to equations” data 

elements in subpart C, rather than being listed separately under subpart A. 

This memorandum documents the EPA’s assessment of the cost impacts associated with the 

proposed revisions to the GHGRP. Section 2.0 of this memorandum contains a description of the 

analyses conducted to estimate cost impacts. Section 3.0 presents the results of the analyses. 

2.0 DESCRIPTION OF ANALYSIS CONDUCTED 

Under this analysis, the EPA estimated the cost of the proposed changes to the GHGRP as the 

incremental costs above the previously estimated costs of the program as promulgated in 2009 

(refer to the 2009 Impacts Analysis)3

. The EPA calculated this incremental cost based on the 

number of reporters that submitted a GHG report in 2011 under each subpart specified in Table 

1. To calculate the incremental cost, the EPA estimated the following for each subpart: (1) the 

cost for each facility to become familiar with the inputs verification tool within e-GGRT, and (2) 

the costs associated with reporting the new data elements. To estimate the number of reporters 

affected by the proposed new data elements, the EPA used the number of reporters that 

submitted a GHG report in 2011 under each of the 10 subparts for which the new data elements 

would be reported. To estimate hourly wages, the EPA used the labor costs per hour for 

technical, managerial, and legal hours specified in the Bureau of Labor Statistics Index for 2011. 

These costs are presented in Table 2. 
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Table 2. Labor Costs - Year 2011 

Labor 

Category Description Hourly Rate ($/hour) 

Legal 

Oversees legal aspects of company reports and data-reporting 

forms. 109.94 

Managerial 

Oversees work at a high level and is the final authority on all 

reporting requirements. 77.23 

Technical 

Conducts monitoring of emissions sources, checks for accuracy, 

performs measurements. 59.12 

Clerical Assists with documentation and recording information 31.35 

2.1 Use of the Electronic Inputs Verification Tool 

The EPA is proposing to eliminate the reporting of many “inputs to equations” data elements, 

due to disclosure concerns. The EPA is proposing to replace these reporting requirements with a 

requirement to enter the data into a new inputs verification tool within e-GGRT. For more 

information on the inputs verification tool, refer to the memorandum documenting the EPA’s 

analysis of alternative verification approaches in docket EPA-HQ-OAR-2010-0929. 1

The EPA has determined that there would be no cost increase to enter “inputs to equations” data 

elements into the inputs verification tool, as compared to the cost associated with reporting these 

data via e-GGRT (i.e., the EPA’s previous cost estimate under the original 2009 rule for 

reporting these data )3. The EPA expects that reporters would spend the same time to complete 

entry of “inputs to equations” data element into the inputs verification tool as they would spend 

reporting these data via e-GGRT. The EPA does recognize, however, that there may be some 

time associated with learning the new procedures for the verification tool. The EPA has 

estimated that each reporter will spend one technical hour to become familiar with the inputs 

verification tool. Based on this technical labor estimate, the associated clerical and managerial 

labor hours2

, and an estimated 5,742 affected reporters (the number of reporters in 2011 under 

one or more of the affected subparts in Table 1)3

, the EPA estimates that using the new inputs 

verification tool would cost approximately $379,244 for the first year. 

2.2 New Data Elements 

In order to facilitate the verification of data, and ensure that the EPA has the information needed 

to better understand emissions associated with reporters, the EPA is proposing that reporters 

 

2

 Clerical and managerial and hours are assumed to be 10 percent and 5 percent, respectively, of technical labor 

hours. 

3

 In 2011, 5,667 reporters reported data elements under subpart C (some of which also reported data elements under 

other subparts listed in Table 1), and 75 additional reporters reported data elements under one or more subparts, 

excluding subpart C, listed in Table 1. 
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under 10 subparts report 26 new data elements (that were not previously required to be reported) 

with their annual report. Table 3 summarizes the new data elements for each subpart and presents 

an analysis of the data availability for each data element. For the 26 data elements added to the 

10 GHG subparts listed in Table 3, the EPA has estimated that 8 of the data elements are 

available from current facility procedures used for accounting purposes or design and purchase 

documents. These data elements are related to annual production or raw material use, and are 

collected by reporters as a routine part of conducting business. The EPA is not proposing to add 

additional monitoring requirements for these data elements, but would allow the use of data 

collected for normal business purposes. Therefore, there will be no additional monitoring cost 

associated with these data elements. The other 18 data elements proposed to be reported are 

values that could be calculated using data currently required to be reported. For example, under 

subpart H, the EPA is proposing to replace the current reporting requirement to report the 

monthly kiln-specific clinker CO2 emission factor for each kiln with a requirement to report the 

annual average clinker CO2 emission factor for the facility, averaged across all kilns. For the 

purposes of reporting the new data element, a reporter under subpart H would calculate an annual 

average facility-wide value based on the current monthly values for all kilns. 

Table 3. New Proposed Data Elements for Part 98 

Subpart New Data Element Analysis of Data Availability 

E - Adipic Acid Annual quantity of cyclohexane fed to all 

production lines (metric tons). 

Available from plant procedures 

used for accounting purposes. 

Raw material consumption is 

necessary for financial accounting 

purposes. 

Annual percent N2O emission reduction for 

all production units combined. 

Calculated value using available 

data for percent emission reduction 

data from each unit. No additional 

measurement required 

G - Ammonia Annual ammonia production (metric tons). Available from plant procedures 

used for accounting purposes. 

Quantity of product produced is 

necessary for financial accounting 

purposes. 

Annual methanol production (metric tons), if 

this quantity is not reported under subpart X. 

Available from plant procedures 

used for accounting purposes. 

Quantity of product produced is 

necessary for financial accounting 

purposes. 

H - Cement Annual clinker production (metric tons). Calculated value using available 

data for monthly clinker 

production currently required for 

emissions equations. No additional 

measurement required. 
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Table 3. New Proposed Data Elements for Part 98 

Subpart New Data Element Analysis of Data Availability 

Annual average clinker CO2 emission factor 

for the facility, averaged across all kilns 

(metric tons CO2/metric ton clinker 

produced). 

Calculated value using available 

data for clinker emission factor for 

each kiln and total clinker 

production. No additional 

measurement required 

Annual average cement kiln dust (CKD) CO2

emission factor for the facility, averaged 

across all kilns (metric tons CO2/metric ton 

CKD produced). 

Calculated value using available 

data for CKD from each kiln. No 

additional measurement required 

P - Hydrogen Name and annual quantity (metric tons) of 

each carbon-containing fuel and feedstock. 

Available from plant procedures 

used for accounting purposes. 

Raw material consumption and 

fuel consumption are necessary for 

financial accounting purposes. 

Annual methanol production (metric tons), if 

this quantity is not reported under subpart X. 

Available from plant procedures 

used for accounting purposes. 

Quantity of product produced is 

necessary for financial accounting 

purposes. 

Q - Iron & Steel If you use the carbon mass balance method 

in §98.173(b)(1) to determine CO2

emissions: The annual mass (metric tons) of 

all gaseous, liquid, and solid fuels 

(combined) used in process units specified in 

Equations Q-1 through Q-7, calculated as 

specified in a proposed new Equation Q-9 in 

the proposed rule amendments. Do not 

include fuel used in a stationary combustion 

unit where emissions are reported under 

subpart C. 

Calculated value using available 

data for mass of each fuel. No 

additional measurement required 

If you use the carbon mass balance method 

in §98.173(b)(1) to determine CO2

emissions: The annual mass (metric tons) of 

all non-fuel material inputs (combined) 

specified in Equations Q-1 through Q-7, 

calculated as specified in a proposed new 

Equation Q-10 in the proposed rule 

amendments. 

Calculated value using available 

data for each non-fuel input. No 

additional measurement required 

If you use the carbon mass balance method 

in §98.173(b)(1) to determine CO2

emissions: The annual mass (metric tons) of 

all solid and liquid products and byproducts 

(combined) specified in Equations Q-1 

through Q-7, calculated as specified in a 

proposed new Equation Q-11 in the proposed 

rule amendments. 

Calculated value using available 

data for each product and 

byproduct. No additional 

measurement required. 
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Table 3. New Proposed Data Elements for Part 98 

Subpart New Data Element Analysis of Data Availability 

If you use the carbon mass balance method 

in §98.173(b)(1) to determine CO2

emissions: The weighted average carbon 

content of all gaseous, liquid, and solid fuels 

(combined) included in proposed new 

Equation Q-9, calculated as specified in a 

proposed new Equation Q-12 in the proposed 

rule amendments. 

Calculated value using available 

data of carbon content for each 

fuel. No additional measurement 

required. 

If you use the carbon mass balance method 

in §98.173(b)(1) to determine CO2

emissions: The weighted average carbon 

content of all non-fuel inputs to all furnaces 

(combined) included in proposed new 

Equation Q-10, calculated as specified in a 

proposed new Equation Q-13 in the proposed 

rule amendments. 

Calculated value using available 

data of carbon content for each 

non-fuel input to each furnace. No 

additional measurement required. 

If you use the carbon mass balance method 

in §98.173(b)(1) to determine CO2

emissions: The weighted average carbon 

content of all solid and liquid products and 

byproducts from all furnaces (combined) 

included in a proposed new Equation Q-11 

in the proposed rule amendments, calculated 

as specified in new Equation Q-14. 

Calculated value using available 

data of carbon content for each 

product and byproduct. No 

additional measurement required. 

S - Lime Annual quantity (metric tons) of lime 

product sold, by type. 

Available from plant procedures 

used for accounting purposes. 

Quantity of product produced is 

necessary for financial accounting 

purposes. 

V - Nitric Acid Annual percent N2O emission reduction for 

all production units combined. 

Calculated value using available 

data of emission reduction for each 

production unit. No additional 

measurement required. 

X - Petrochemicals If using the mass balance method or CEMS 

method to calculate GHG emissions: Name 

and annual quantity (in metric tons) of each 

carbon-containing. 

Calculated value using available 

data of monthly quantities of 

feedstocks. No additional 

measurement required. 

If using the mass balance method or CEMS 

method to calculate GHG emissions: Name 

and annual quantity (in metric tons) of each 

carbon-containing co-product. 

Calculated value using available 

data of monthly quantities of coproducts. No additional 

measurement required. 

Y - Refineries Annual quantity of flare gas combusted (in 

MMscf per year) (only when using Equation 

Y-3). 

Calculated value using available 

data of annual volumes of flare gas 

during normal operations and 

during SSM events. No additional 
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Table 3. New Proposed Data Elements for Part 98 

Subpart New Data Element Analysis of Data Availability 

measurement required. 

Annual average molecular weight of flare 

gas combusted (in mmBtu per MMscf) (only 

when using Equation Y-3). 

Calculated using known 

composition of flare gas during 

normal operations and during SSM 

events. No additional measurement 

required. 

Annual average carbon content of flare gas 

combusted (expressed as a decimal 

fraction)(only when using Equation Y-3). 

Calculated using known 

composition of flare gas during 

normal operations and during SSM 

events. No additional measurement 

required. 

AA - Pulp & Paper For each pulp mill lime kiln: Quantity of 

calcium oxide (CaO) produced (metric tons). 

Available from plant procedures 

used for accounting purposes. 

Quantity of product produced is 

necessary for financial accounting 

purposes. 

For each pulp mill lime kiln: Percent of 

annual heat input, individually for each fossil 

fuel type. 

Calculated using known quantities 

of fuel and heat value of fuel. No 

additional measurement required. 

For each chemical recovery furnace and 

chemical recovery combustion unit for 

which you are not using Equation C-2c to 

calculate CO2 emissions: Annual mass of 

steam generated (lb steam), individually for 

each fossil fuel type and for spent liquor 

solids. 

Calculate using known quantities 

of fuel and heat value of fuel. No 

additional measurement required. 

For each chemical recovery furnace and 

chemical recovery combustion unit for 

which you are not using Equation C-2c to 

calculate CO2 emissions: Ratio of the unit’s 

maximum rated heat input capacity to its 

design rated steam output capacity 

(mmBtu/lb steam), individually for each 

fossil fuel type and for spent liquor solids. 

Data readily available from design 

or purchase documents. No 

additional measurement required. 

For data elements that would be readily available to the facilities, the EPA has estimated 

that there is little cost to the reporter to acquire the data and report the values during the reporting 

process. For data elements for which the underlying data (used to calculate the data element) are 

currently being reported, and only a simple change to a calculation spreadsheet would be 

required to fulfill the reporting requirement, the EPA has estimated a nominal additional cost to 

report the data element. For each of the proposed new data elements, the EPA estimated that 

reporters would annually spend 0.5 technical hours per data element for proposed reporting 
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requirements. The EPA estimated that legal and managerial hours would be 5 percent and 10 

percent, respectively, of the technical hours. The EPA estimated the number of reporters based 

on the annual reports received in 2011 for the 10 subparts.2 Table 4 shows the number of 

affected reporters by subpart and the number of data elements to be reported for each subpart. 

Based on these data, the total estimated costs associated with reporting for the 26 data elements 

in the 10 subparts listed in Table 4 is $80,000. 

 Table 4. Subparts with New Data Elements Reported 

Subpart Source Category 

Number of New Data 

Elements Number of Reporters 

E Adipic Acid Production 2 3 

G Ammonia Manufacturing 2 22 

H Cement Production 3 98 

P Hydrogen Production 2 103 

Q Iron and Steel Production 6 128 

S Lime Manufacturing (non-CEMS) 1 73 

V Nitric Acid Production 1 35 

X Petrochemical Production 2 64 

Y Petroleum Refineries 3 145 

AA Pulp and Paper Manufacturing 4 110 

2.3 Recordkeeping changes 

The proposed changes to the GHGRP include a provision to retain records of all “inputs to 

equations” data elements for five years instead of the three years currently required. 

Additionally, the EPA is requiring reporters who use the inputs verification tool to maintain a 

record of a file generated by the tool, which lists the entered “inputs to equations” data elements. 

This list of data elements could be maintained in a format (e.g., electronic, hard copy) currently 

allowed under Part 98. The EPA does not anticipate that this change to the recordkeeping 

requirements would create any additional burden for a reporting facility in addition to the 

recordkeeping burden estimated in the 2009 Impact Analysis.3

 

3.0 RESULTS OF ANALYSIS 

The total cost of the proposed changes is presented in Table 5. The EPA estimates that the first 

year net cost would be $460,000, which includes the one-time cost of learning the verification 

system. The EPA estimates recurring costs to be $80,000 for reporting of new data elements. 
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Table 5. Summary of Changes to Costs of GHGRP for 2015 Inputs Proposal 

Cost Element First Year Costs Subsequent Year Costs 

Verification tool (training) $380,000 

Reporting for New Data Elements $ 80,000 $80,000 

Net Cost $420,000 $80,000

4.0 REFERENCES 

1. Evaluation of Alternative Verification Approaches for Greenhouse Gas Reporting Rule 

Subparts for which Reporting of Inputs to Emission Equations was Deferred to March 31, 

2015. Memorandum from Lisa Grogan-McCulloch, U.S. EPA to Docket EPA-HQ-OAR2010-0929. August 2013. 

2. 2011 Greenhouse Gas Emissions from Large Facilities. 

http://ghgdata.epa.gov/ghgp/main.do . 

3. Regulatory Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions 

Final Rule (GHG Reporting). U.S. Environmental Protection Agency. September 2009.