2015 Revisions and 

Confidentiality Determinations for Data Elements under the GHG Reporting Rule; Proposed Rule 

Interagency Briefing October 15, 2015
Overview

• Background• Proposal Elements

– Types of revisions, organization, and subparts cov– Revisions due to Waste Management petition– Revisions to subpart FF - Underground Coal Mine– Revisions to improve data quality– Revisions to streamline implementation– Other proposed revisions– CBI Determinations

• Proposed Timeline for Implementation• Impacts of Proposal

DRAFT - DELIBERATIVE - 
Background on GHG Reporting 

Program• Well-known, reliable source for high-quality, ti

emissions data that enables entities to understemissions, identify reduction opportunities, anaction

• Overall, 8,600 facilities across all sectors are re

annually, accounting for 85-90% of U.S. GHG e

• Covers 41 sectors including both direct emitte

suppliers.

DRAFT - DELIBERATIVE - 
Background

• Rule was published in 2009, requires reporting of GHGs 

with 2008 Consolidated Appropriations Act.

• Later, EPA proposed and finalized several amendments 

subparts to improve clarity and consistency of calculatiomonitoring, and reporting

– Improve GHGRP and address issues identified during implemen

EPA, reporters, and other stakeholders.

– Many actions specific to certain subparts

• Last set of general revisions to the GHGRP were done in 

combination with the change in GWPs to match AR4 val

– Finalized in November 2013; Effective January 2014 for RY2013– Covered corrections/amendments to many subparts

DRAFT - DELIBERATIVE - D
Types of Revisions Being Proposed 

• Revisions to streamline implementation and 

burden

• Revisions to improve quality of the data repo• Amendments to better reflect industry proce

emissions

– Including those based on prior petitions and past 

• Minor clarifications and corrections to impro

understanding of the rule

DRAFT - DELIBERATIVE - 
How Preamble is Organized

• Up front overview of 4 types of revisions (with exampl• Body is organized by subpart and type of revision• Revisions that are true corrections, i.e., limited explana

needed, are in supporting memo “Table of Revisions.” 

– Table contains all revisions and provides explanatio

preamble if explanation can be found there.

• Section on CBI Determinations

– Only those that do not have categorical determinat– Supporting memo with all categorizations and dete

• Impacts

DRAFT - DELIBERATIVE - 
Subparts 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-23 

Destruction (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 • Soda Ash Manufacturing (C• Use of Electric Transmission 

Distribution Equipment (DD

• Underground Coal Mines (F• MSW Landfills (HH)• Industrial Wastewater Trea• Suppliers of Coal-Based Liqu• Suppliers of Petroleum Prod• Suppliers of Natural Gas and 

Liquids (NN)

• Suppliers of Industrial GHGs • Suppliers of CO

2 (PP)*

• Geologic Sequestration of C

• Industrial Waste Landfills (T• Injection of CO2 (UU)*

DRAFT - DELIBERATIVE - 
Revisions in Response to Petition 

from Waste Management

• Administrative petition for reconsideration re

January 2014 on the Final 2013 Revisions

– Asking us to reconsider the minimum soil cover re

in order to use higher soil oxidation fractions in c

emissions from MSW landfills

• Preamble discusses issue, review and analysis 

undertaken, and changes being proposed in r

– Result: proposing to remove the numerical soil co

requirement, replacing it with references to stateintermediate soil cover requirements 

• EPA intends to complete our response to this 

through this rulemaking DRAFT - DELIBERATIVE - D
Revisions for Underground Coal Mine

• Proposing to no longer allow MSHA quarterly 

inspection reports for monitoring methane libfrom ventilation.

– Evaluated emissions for 30 highest emitting mine

determined that MSHA, while good for mine safereliable for GHG reporting

• Mines would need to use one of 2 other meth

the rule: CEMS or independently collected sa

– Grab samples must be monthly, not quarterly, to 

more accurate and reliable data

– Several mines already conduct monthly monitorin

• Add reporting of coal production data for ver

DRAFT - DELIBERATIVE - 
Revisions to Improve Data Quality

• Ensure accuracy of data submitted

– Subpart FF - change monitoring requirements– Subpart Y – new methodology for determining emissions from 

coking units (DCUs)

• Collect more detailed data for a more accurate emissio

– Subpart O - collect data at the process level instead of facility – Subpart I - collect additional data in Triennial Report

• Improve verification

– Subpart HH - collect one more data element to allow e-GGRT 

calculations and reduce verification effort

• Support GHG Inventory

– Subparts E & V - collect date of installation of abatement syst

accurately apply emission factors to time series

– Subpart V - add reporting from high-strength nitric acid facilit

completeness of the Inventory

DRAFT - DELIBERATIVE - D
Revisions to Streamline 

Implementation and Reduce Burden

• “Abandoned” coal mines would no longer be 

to report

• Pilot gas from flares would be excluded from 

calculations for Q, X, and Y

• Propose removing reporting requirements fro

several subparts that are no longer necessary

• Clarify that suppliers can also discontinue rep

they no longer meet the thresholds for 3 or 5 

• Users of alternative monitoring for subparts E 

would not need to reapply each year

DRAFT - DELIBERATIVE - 
Other Proposed Revisions

• In response to petition from Waste Managem• In response to past comments on rules that w

of scope

– Subpart TT to provide more detailed emission fac

industrial landfills at pulp and paper facilities per from AF&PA and the American Wood Council

– Subpart AA to allow use of a measured value from 

regulation as an acceptable missing data estimate combustion unit for spent liquor solids.

DRAFT - DELIBERATIVE - 
CBI Determinations

• Proposing CBI Determinations for

– New reporting requirements– Substantially revised reporting requirements– Certain data elements for which we did not previ

propose or finalize a determination

• Followed same methodology as before

– Assign elements to a data category – Then assign either a categorical determination or 

individual determination

– See previous rules (listed in section IV.A. of draft 

DRAFT - DELIBERATIVE - DO 
Proposed Effectiveness Timeline

• Phased-in over 3 years

– Later date required for those revisions that chang

monitoring requirements or add reporters

– Allow time for integration into e-GGRT for revisio

less time sensitive 

– Proposal needs to be signed by mid-December to 

schedule

DRAFT - DELIBERATIVE - D

Reporting Year* Date Collected Subpart

2016 March 31, 2017 I, HH, and one definition in A (rele2017 March 31, 2018 A, C, E, F, G, N, O, P, Q, S, U, X, Z, A

FF, II, LL, MM, NN, PP, RR, TT, and 

2018 March 31, 2019 V, Y, OO, and Table A-5 (relevant to 

*Data monitored in a Reporting Year is submitted to EPA by March 31 of the subsequen

Proposed Timeline for Revisions
Impacts of Proposal - Methodology

• Examined burden impact of different amendment

– Changes to add, revise, or remove reporting requirements– Revisions to monitoring requirements such that facilities wou

additional data (subpart FF)

– Revisions to applicability such that additional facilities would 

report (subparts V and OO)

• Looked at each subpart by amendment type and for ea

staggered implementation

• Confidentiality determinations do not impact burde

n

• Detailed in supporting memo: “Assessment of Burden 

2015 Revisions to the Greenhouse Gas Reporting Rule

”

DRAFT - DELIBERATIVE - D
Impacts of Proposal

Cost Summary 2016 2017 2018 First Year Costs $9,359 $4,379,195

a $121,719

b 

Subsequent Year Annual Costs for Changes Implemented in:

2016 -- $9,359 $9,359 2017 -- -- $3,770,300 2018 -- -- -- 

Total Costs by year (all subparts)

$9,359 $4,388,553 $3,901,378 

DRAFT - DELIBERATIVE - D

a Includes one-time implementation costs for new monitoring under subpart b Includes one-time implementation costs for new reporters under subparts V