MEMORANDUM

TO: Debbie Ottinger, EPA

FROM: Carrie Richardson Fry and Karen Schaffner, RTI

DATE: July 14, 2014

SUBJECT: Economic Analysis of Adding Chemical-Specific and Default GWPs to Table A-1

Proposed changes to the Greenhouse Gas Reporting Rule, including updates to subpart A 

and conforming changes to subpart I and subpart L, were evaluated to determine their economic 

impacts on facilities covered by the subparts related to emissions or supply of fluorinated GHGs 

and HTFs. The proposed changes include the addition of both chemical specific and default 

GWPs for fluorinated GHGs that are not currently listed on Table A-1 of subpart A. These 

GWPs would be added to Table A-1.

Impact of Added Chemical-Specific and Default GWPs on Rule Applicability. All of the 

GHGs to which the new chemical-specific and default GWPs would be applied are fluorinated 

GHGs. Nine subparts cover industries that emit or supply fluorinated GHGs. We have 

concluded that the applicability of these subparts would not be affected by EPA’s proposed 

addition of chemical-specific and default GWPs. Table 1 summarizes the rationale for this 

assessment.

Table 1. Rationale for Assessment of Impact

Subpart

Not Affected / 

Affected by 

Addition of 

GWPs Rationale

F – Aluminum Production Not Affected

All facilities must report - no threshold; also, 

fluorinated GHGs emitted are not affected by this 

action

I – Electronics Manufacturing Not Affected Threshold based on emissions of fluorinated GHGs 

whose GWPs are not affected by this action

L - Fluorinated Gas Production Not Affected

All facilities covered by subpart already expected to 

be above threshold. Facilities producing fluorinated 

anesthetics, which currently fall below the threshold, 

will not experience an increase in GWPs.

O - HCFC-22 Production and HFC-23

Destruction Not Affected Threshold not based on CO2e; also, fluorinated GHG emitted is not affected by this action

T – Magnesium Production Not Affected

CO2e emissions overwhelmingly dominated by 

fluorinated GHGs whose GWPs are not affected by 

this action. (Affected GHGs comprise less than one 

percent of one facility’s CO2e emissions.)
Table 1. Rationale for Assessment of Impact

Subpart

Not Affected / 

Affected by 

Addition of 

GWPs Rationale

DD - Use of Electric Transmission and 

Distribution Equipment Not Affected Threshold not based on CO2e; also, fluorinated GHGsemitted are not affected by this action

OO - Suppliers of Industrial 

Greenhouse Gases Not Affected All importers/exporters of affected fluorinated GHGs are already expected to be above thresholda

QQ - Imports and Exports of 

Equipment Pre–charged with 

Fluorinated GHGs or Containing 

Fluorinated GHGs in Closed–cell 

Foams

Not Affected

CO2e supplies overwhelmingly dominated by 

fluorinated GHGs whose GWPs are not affected by 

this action

SS - Manufacture of Electric 

Transmission and Distribution 

Equipment

Not Affected Threshold not based on CO2e; fluorinated GHGs

emitted are not affected by this action

aThe fluorinated GHGs that are covered by this action and that have significant GWPs are specialty gases used in 

niche applications as opposed to widely used commodities, and the set of importers and exporters of these GHGs is 

consequently expected to be small and limited to those already identified as supplying those niche applications. All 

of these importers and exporters already report under subpart OO. 

Impact of Added Chemical-Specific and Default GWPs on Subpart I and Subpart L 

Requirements. Subpart I and subpart L both require facilities to perform preliminary calculations 

to determine whether the CO2e emissions from a stack system or vent, respectively, exceed a 

threshold or cutoff. If the cutoff is exceeded, the facility is required to perform emission testing 

rather than to use an alternative emission estimation approach. In these preliminary 

calculations, subpart L and subpart I both require facilities to use a default GWP of 2,000 for 

fluorinated GHGs that do not have GWPs on Table A-1. For both subparts, EPA is proposing to 

replace the default GWP of 2,000 with the chemical-specific and default GWPs that would be 

added to Table A-1, which range from less than 1 to 10,000. 

For subpart I we have concluded that any impacts on facilities reporting under subpart I 

were accounted for in the most recent economic analysis for subpart I (EPA-HQ-OAR-2012-

0934). The burden estimates in that analysis were based on the assumptions that facilities would 

use the correct GWPs in their calculations, accurately calculate their CO2e emissions, and

appropriately categorize all stack systems as above or below the cutoff. In any event, EPA’s 

analysis has shown that the impact of the new GWPs on the calculated CO2e stack emissions of 

individual facilities is likely to be very small. Based on an analysis of reporting year 2012 

emissions, only one facility would see an increase in calculated CO2e stack emissions. That 

increase would be about 30 mtCO2e, or 0.2 percent of the facility’s fluorinated GHG stack 

emissions. Fifteen facilities would see a decrease in calculated CO2e emissions, with the largest 

decrease being about 700 mtCO2e. 
For subpart L we have also concluded that any impacts on facilities were accounted for 

in the initial economic analysis for subpart L. The initial economics evaluation for subpart L 

assumed that the affected facilities were using GWPs that accurately reflected the actual GWPs 

of the emitted compounds when performing the applicability calculations required as a part of 

the subpart L rule. We assumed the facilities were accurately calculating their CO2e emissions

and that all process vents were appropriately categorized above or below the cutoff. Therefore,

the addition of GWPs to Table A-1 of subpart A is not expected to increase the costs incurred by 

subpart L facilities above those initially calculated for subpart L.