2015 Revisions andConfidentialityDeterminations for DataElements under theGHG Reporting Rule;Proposed RuleInteragency BriefingOctober 15, 2015Overview• Background• Proposal Elements– Types of revisions, organization, and subparts covered– Revisions due to Waste Management petition– Revisions to subpart FF - Underground Coal Mines– Revisions to improve data quality– Revisions to streamline implementation– Other proposed revisions– CBI Determinations• Proposed Timeline for Implementation• Impacts of ProposalDRAFT - DELIBERATIVE - DO NOT CITE OR QUOTE2Background on GHG ReportingProgram• Well-known, reliable source for high-quality, timely GHGemissions data that enables entities to understandGHGemissions, identify reduction opportunities, and takeaction• Overall, 8,600 facilities across all sectors are reportingannually, accounting for 85-90% of U.S. GHG emissions.• Covers 41 sectors including both direct emitters andsuppliers.DRAFT - DELIBERATIVE - DO NOT CITE OR QUOTE3Background• Rule was published in 2009, requires reporting ofGHGs consistentwith 2008 Consolidated Appropriations Act.• Later, EPA proposed and finalized several amendments to varioussubparts to improve clarity and consistency of calculations,monitoring, and reporting– Improve GHGRP and address issues identified duringimplementation byEPA, reporters, and other stakeholders.– Many actions specific to certain subparts• Last set of general revisions to the GHGRP were done incombination with the change in GWPs to match AR4 values– Finalized in November 2013; Effective January 2014for RY2013– Covered corrections/amendments to many subpartsDRAFT - DELIBERATIVE - DO NOT CITE OR QUOTE4Types of Revisions Being Proposed• Revisions to streamline implementation and reduceburden• Revisions to improve quality of the data reported• Amendments to better reflect industry processes andemissions– Including those based on prior petitions and pastcomments• Minor clarifications and corrections to improveunderstanding of the ruleDRAFT - DELIBERATIVE - DO NOT CITE OR QUOTE5How Preamble is Organized• Up front overview of 4 types of revisions (with examples)• Body is organized by subpart and type of revision• Revisions that are true corrections, i.e., limitedexplanationneeded, are in supporting memo “Table of Revisions.”– Table contains all revisions and provides explanations; refers topreamble if explanation can be found there.• Section on CBI Determinations– Only those that do not have categorical determinations– Supporting memo with all categorizations and determinations• ImpactsDRAFT - DELIBERATIVE - DO NOT CITE OR QUOTE6Subparts Covered in the Proposal* Only have minor corrections listed in Table of Revisions• General Provisions (A)• Stationary Combustion (C)• Adipic Acid Production (E)• Aluminum Production (F)• Ammonia Manufacturing (G)• Electronics Manufacturing (I)• Glass Production (N)• HCFC-22 Production and HFC-23Destruction (O)• Hydrogen Production (P)*• Iron and Steel Manufacturing (Q)• Lime Manufacturing (S)• Miscellaneous Use of Carbonate (U)*• Nitric Acid Production (V)• Petrochemical Production (X)• Petroleum Refineries (Y)• Phosphoric Acid Production (Z)• Pulp & Paper Manufacturing (AA)• Soda Ash Manufacturing (CC)• Use of Electric Transmission andDistribution Equipment (DD)• Underground Coal Mines (FF)• MSW Landfills (HH)• Industrial Wastewater Treatment (II)• Suppliers of Coal-Based Liquid Fuels (LL)• Suppliers of Petroleum Products (MM)*• Suppliers of Natural Gas and Natural GasLiquids (NN)• Suppliers of Industrial GHGs (OO)• Suppliers of CO2(PP)*• Geologic Sequestration of CO2(RR)• Industrial Waste Landfills (TT)• Injection of CO2(UU)*DRAFT - DELIBERATIVE - DO NOT CITE OR QUOTE7Revisions in Response to Petitionfrom Waste Management• Administrative petition for reconsideration received inJanuary 2014 on the Final 2013 Revisions– Asking us to reconsider the minimum soil cover requirementin order to use higher soil oxidation fractions incalculatingemissions from MSW landfills• Preamble discusses issue, review and analysisundertaken, and changes being proposed in response– Result: proposing to remove the numerical soil coverrequirement, replacing it with references to state-levelintermediate soil cover requirements• EPA intends to complete our response to this petitionthrough this rulemakingDRAFT - DELIBERATIVE - DO NOT CITE OR QUOTE8Revisions for Underground Coal Mines• Proposing to no longer allow MSHA quarterlyinspection reports for monitoring methane liberatedfrom ventilation.– Evaluated emissions for 30 highest emitting minesanddetermined that MSHA, while good for mine safety, is notreliable for GHG reporting• Mines would need to use one of 2 other methods inthe rule: CEMS or independently collected samples– Grab samples must be monthly, not quarterly, to ensuremore accurate and reliable data– Several mines already conduct monthly monitoring• Add reporting of coal production data for verificationDRAFT - DELIBERATIVE - DO NOT CITE OR QUOTE9Revisions to Improve Data Quality• Ensure accuracy of data submitted– Subpart FF - change monitoring requirements– Subpart Y – new methodology for determining emissions from delayedcoking units (DCUs)• Collect more detailed data for a more accurate emissions profile– Subpart O - collect data at the process level instead of facility level– Subpart I - collect additional data in Triennial Report• Improve verification– Subpart HH - collect one more data element to allowe-GGRT to docalculations and reduce verification effort• Support GHG Inventory– Subparts E & V - collect date of installation of abatement system toaccurately apply emission factors to time series– Subpart V - add reporting from high-strength nitricacid facilities to improvecompleteness of the InventoryDRAFT - DELIBERATIVE - DO NOT CITE OR QUOTE10Revisions to StreamlineImplementation and Reduce Burden• “Abandoned” coal mines would no longer be requiredto report• Pilot gas from flares would be excluded from emissionscalculations for Q, X, and Y• Propose removing reporting requirements fromseveral subparts that are no longer necessary• Clarify that suppliers can also discontinue reporting ifthey no longer meet the thresholds for 3 or 5 years• Users of alternative monitoring for subparts E & Vwould not need to reapply each yearDRAFT - DELIBERATIVE - DO NOT CITE OR QUOTE11Other Proposed Revisions• In response to petition from Waste Management• In response to past comments on rules that were outof scope– Subpart TT to provide more detailed emission factors forindustrial landfills at pulp and paper facilities per a commentfrom AF&PA and the American Wood Council– Subpart AA to allow use of a measured value from anotherregulation as an acceptable missing data estimate from acombustion unit for spent liquor solids.DRAFT - DELIBERATIVE - DO NOT CITE OR QUOTE12CBI Determinations• Proposing CBI Determinations for– New reporting requirements– Substantially revised reporting requirements– Certain data elements for which we did not previouslypropose or finalize a determination• Followed same methodology as before– Assign elements to a data category– Then assign either a categorical determination ormake anindividual determination– See previous rules (listed in section IV.A. of draft preamble).DRAFT - DELIBERATIVE - DO NOT CITE OR QUOTE13Proposed Effectiveness Timeline• Phased-in over 3 years– Later date required for those revisions that changemonitoring requirements or add reporters– Allow time for integration into e-GGRT for revisions that areless time sensitive– Proposal needs to be signed by mid-December to meet thisscheduleDRAFT - DELIBERATIVE - DO NOT CITE OR QUOTE14Reporting Year* Date Collected Subpart2016 March 31, 2017 I, HH, and one definition in A (relevant to HH)2017 March 31, 2018 A, C, E, F, G, N, O, P, Q, S, U,X, Z, AA, CC, DD,FF, II, LL, MM, NN, PP, RR, TT, and UU2018 March 31, 2019 V, Y, OO, and Table A-5 (relevantto OO)*Data monitored in a Reporting Year is submitted toEPA by March 31 of the subsequent calendar yearProposed Timeline for RevisionsImpacts of Proposal - Methodology• Examined burden impact of different amendment– Changes to add, revise, or remove reporting requirements– Revisions to monitoring requirements such that facilities would to collectadditional data (subpart FF)– Revisions to applicability such that additional facilities would be required toreport (subparts V and OO)• Looked at each subpart by amendment type and for each year ofstaggered implementation• Confidentiality determinations do not impact burden• Detailed in supporting memo: “Assessment of BurdenImpacts of2015 Revisions to the Greenhouse Gas Reporting Rule”DRAFT - DELIBERATIVE - DO NOT CITE OR QUOTE15Impacts of ProposalCost Summary 2016 2017 2018 2019First Year Costs $9,359 $4,379,195a$121,719b--Subsequent Year Annual Costs for Changes Implemented in:2016 -- $9,359 $9,359 $9,3592017 -- -- $3,770,300 $3,770,3002018 -- -- -- $94,975Total Costs by year(all subparts)$9,359 $4,388,553 $3,901,378 $3,874,634DRAFT - DELIBERATIVE - DO NOT CITE OR QUOTE16aIncludes one-time implementation costs for new monitoring under subpart FF.bIncludes one-time implementation costs for new reporters under subparts V and OO.