Page 1 November 2014 

SUPPORTING STATEMENT 

ENVIRONMENTAL PROTECTION AGENCY 

Greenhouse Gas Reporting Rule: 2015 Revisions and Confidentiality Determinations for 

Petroleum and Natural Gas Systems; Proposed Rule 

(40 CFR Part 98, subpart W) 

November 2014 

Part A of the Supporting Statement 

1. IDENTIFICATION OF THE INFORMATION COLLECTION 

1(a) Title and Number of the Information Collection

Recordkeeping and Reporting Requirements for Petroleum and Natural Gas Systems (40 

CFR part 98, Subpart W). The OMB Control number is 2060-0629 and the EPA ICR tracking 

number is 2300.16. 

1(b) Short Characterization 

In response to the FY2008 Consolidated Appropriations Act (H.R. 2764; Public Law 

110-161) and under authority of the Clean Air Act (CAA), the 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 (hereafter referred to as “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: 2015 

Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems” (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). 
Page 2 November 2014 

The EPA is proposing to add reporting requirements for two new industry segments, add 

reporting requirements for completions and workovers of oil wells with hydraulic fracturing, and 

add requirements to report well identification numbers for certain sources. These proposed 

revisions are expected to increase respondent burden. See Appendix A for a complete list of 

proposed additions to the reporting requirements. 

Potential new respondents are owners or operators of petroleum and natural gas systems 

that meet the requirements of §98.2(a)(2) and the reporting thresholds of §98.231. New 

respondents are required to report data elements according to §98.236, and maintain records 

according to §98.237. Existing respondents must report and maintain records as specified in Part 

98. 

Approximately 3,300 respondents will be subject to the regulation and this rulemaking is 

expected to increase labor costs for subpart W facilities. Compared with the estimated respondent 

burden identified in the information collection for the GHGRP currently approved by the Office of 

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

increase in annual burden of 73,000 hours and $7.2 million, as shown in Section 6. 

 
Page 3 November 2014 

2. NEED FOR AND USE OF THE COLLECTION 

2(a) Need/Authority for the Collection 

The FY2008 Consolidated Appropriations Act, signed into law on December 26, 2007, 

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.” 

As stated in the October 30, 2009 preamble to Part 98 (74 FR 56260), 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. 

Therefore, the EPA is proposing this information collection under the authority provided in 

CAA section 114. 

2(b) Use /Users of the Data 

The GHGRP 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 accessible to the 

public at: http://ghgdata.epa.gov/ghgp/main.do. Reporting entities generally 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 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 
Page 4 November 2014 

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. 

Generally, 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. 

Specifically, subpart W data can be used to complement atmospheric GHG studies and 

inform updates to emission inventories. Various activity data are collected that can be used to 

improve understanding of the occurrence of emissions from a variety of sources. 

 
Page 5 November 2014 

3. NONDUPLICATION, CONSULTATIONS AND OTHER COLLECTION 

CRITERIA 

3(a) Nonduplication 

The information to be collected under the proposed revisions includes 232 new data 

elements (refer to Appendix A for a list of these data elements). These proposed new data elements 

consist primarily of quantities related to 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 

elements for subpart W are similar to the types of industry data already being collected under the 

GHGRP. The EPA has evaluated the types of industry data collected under Part 98, and concluded 

that they do not duplicate other information collections, as described below. 

In developing the GHGRP, the 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 

• IPCC Guidelines for National Greenhouse Gas Inventories. 

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 
Page 6 November 2014 

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, the EPA has made significant efforts over the past 

four years to facilitate reporting in the event a single entity has to report both the federal and state 

level. For example, the 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 the EPA’s GHGRP. The product of the collaboration is referred to as California Electronic 

Greenhouse Gas Reporting Tool, or Cal e-GGRT. 

Documentation of the 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 

Docket ID No. EPA-HQ-OAR-2008-0508. For further discussion on the relationship of the 

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

June 6, 2008 memorandum entitled “Review of Existing Programs” (Docket Item No. 

EPA-HQ-OAR-2008-0508-0052), and the January 27, 2009 memorandum entitled “Review of 

Existing State Greenhouse Gas Reporting Rules” (Docket Item No. 

EPA-HQ-OAR-2008-0508-0054). Some GHG programs are described below: 

• A number of the 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 the EPA learn more about emissions from facilities not included in 

current programs. 

• The 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. 

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. 
Page 7 November 2014 

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: 2015 Revisions and Confidentiality Determinations for Petroleum and 

Natural Gas Systems; Proposed Rule.” 

3(c) Consultations 

Early in the development process of the GHGRP, the EPA conducted a proactive 

communications outreach program to inform the public about the rule development effort. The 

EPA solicited input and maintained an open-door policy for those interested in discussing the 

rulemaking. Since January 2008, the EPA staff has held more than 100 meetings with 

stakeholders, including the following: 

• 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. 

The 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), the EPA proposed the GHGRP. The EPA held two 

public hearings, and received more than 16,000 written public comments. The public comment 

period ended on June 9, 2009. Comments related to Subpart W were received 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 Docket ID No. 

EPA-HQ-OAR-2009-0923. Following promulgation of the final subpart W rule (75 FR 74458, 
Page 8 November 2014 

November 30, 2010), the 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, November 29, 2013; 79 FR 63750, October 24, 

2014; and 79 FR 70352, November 25, 2014). 

In the current action, the EPA is proposing to revise certain petroleum and natural gas 

systems source category GHG reporting requirements. The proposed changes would add reporting 

requirements for two new industry segments (Onshore Natural Gas Transmission Pipelines and 

Onshore Petroleum and Natural Gas Gathering and Boosting), add reporting requirements for 

completions and workovers of oil wells with hydraulic fracturing, and add requirements to report 

well identification numbers for certain sources. 

In conjunction with this action, we are proposing confidentiality determinations for the 

new data elements contained in these proposed amendments. 

3(d) Effects of Less Frequent Collection 

The frequency for reporting emissions information to the 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. If the 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 is consistent with all OMB guidelines under 5 CFR 1320.5. 
Page 9 November 2014 

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, the 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, the 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, 75 FR 39094, 

July 7, 2010 39094 and final CBI rule, May 26, 2011, 76 FR 30782). 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 the 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) and 79 FR 70352 

(November 25, 2014). In the current action, the EPA is proposing confidentiality determinations 

for the new data elements contained in these proposed amendments. 

3(g) Sensitive Questions 

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

Part 98 do not include sensitive questions. 

 
Page 10 November 2014 

4. THE RESPONDENTS AND THE INFORMATION REQUESTED 

The respondents in this information collection include owners and operators of petroleum 

and natural gas systems facilities that must report their GHG emissions to the 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 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 NAICS code in Table 1. The NAICS codes are not 

exhaustive, but rather provide a list of facilities likely to be affected. 

Table 1. NAICS codes for affected reporters 

Part and Subpart NAICS codes 

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. The EPA is proposing that 232 new data elements be reported. Table 1 of 

Appendix A specifies each new data element that would be reported by industry segment. 

(ii) Respondent Activities. The owner or operator of a facility that is subject to the subpart 

W reporting requirements must report total annual GHG emissions. The primary tasks that 

reporting program respondents perform include: 

1. Implementing and updating, as necessary, appropriate monitoring plans for each 

affected source and each affected unit at a source, as applicable; 
Page 11 November 2014 

2. Conducting 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 the EPA; 

4. Potentially responding to questions or error messages from the 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 emission data (this activity generally is performed 

electronically). 

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

segment separately. Reporters are required to provide emissions in metric tons of methane (CH4), 

CO2, and nitrous oxide (N2O) for some sources and in metric tons of CO2e for other sources. The 

calculations used to determine GHG emissions, the frequency at which those calculations are 

required, and the methods used to estimate missing data depend on the specific subpart W industry 

segment. 

(iii) Electronic Reporting. Respondents report all data electronically through the 

Electronic Greenhouse Gas Reporting Tool (e-GGRT). All new data elements will be reported in 

the same way. As the e-GGRT accounts are already established, the only burden related to 

electronic reporting will be entering the data elements. 

 
Page 12 November 2014 

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 data elements was estimated. 

5(b) Collection Methodology and Management 

To collect data currently reported under the GHGRP, the EPA previously established a 

central repository of inventory data for all respondents called the e-GGRT. Respondents report 

data electronically, and the EPA stores the data in the database. The e-GGRT system provides a 

user interface for entering the GHG data and also has an XML reporting schema that allows 

facilities to upload GHG data directly. Under the proposed revisions to Part 98, facilities subject to

subpart W listed in Section 4(a) would report the proposed new data elements via e-GGRT. 

The e-GGRT system follows Agency standards for design, security, data element and 

reporting format conformance, and accessibility. The EPA designed the system 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. As part of the proposal process for this rule package, the EPA conducted 

a screening assessment comparing compliance costs to onshore petroleum and natural gas 

production specific receipts data for establishments owned by small businesses. This ratio 

constitutes a “sales” test that computes the annualized compliance costs of this rule as a percentage 

of sales and determines whether the ratio exceeds 1 percent. The cost-to-sales ratios were 

constructed at the establishment level (average reporting program costs per establishment/average 
Page 13 November 2014 

establishment receipts) for several business size ranges. This allowed the EPA to account for 

receipt differences between establishments owned by large and small businesses and differences in 

small business definitions across affected industries. 

The cost-to-sales ratios are less than 1 percent for all establishments, except the ratio for 

the 1–20 employee range for facilities in the Onshore Petroleum and Natural Gas Production 

segment with NAICS code 213111, which is 1 percent, and the ratios for the 1–20 employee range 

for facilities in the Onshore Petroleum and Natural Gas Production and Onshore Petroleum and 

Natural Gas Gathering and Boosting segments with NAICS code 213112, which are greater than 1 

percent but less than 2 percent. The petroleum and natural gas industry has a large number of 

enterprises, the majority of them in the 1–20 employee range. However, a large fraction of 

production comes from large corporations and not those with less than 20 employee enterprises. 

The smaller enterprises in most cases deal with very small operations (such as a single family 

owning a few production wells) that are unlikely to cross the 25,000 metric tons CO2e threshold 

considered for the rule. An exception to such a scenario is a small (less than 20 employee) 

enterprise owning large operations but conducting nearly all of its operations through contractors. 

This is not an uncommon practice in the Onshore Petroleum and Natural Gas Production segment. 

Such enterprises, however, are a very small group among the almost 16,000 enterprises in the less 

than 20 employee category, and the EPA proposes to cover them in the rule. 

Therefore, this rule will not have a significant economic impact on a substantial number of 

small entities. 

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. 

 
Page 14 November 2014 

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

This section presents the 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 

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. The EPA estimates that the total 

annual burden to all affected entities is 63.4 hours per year over the three years covered by this 

information collection. There are expected to be approximately 400 new reporters will become 

subject to subpart W as a result of these amendments. Exhibit 6.1 presents aggregate burden and 

burden by subpart W industry segment. 

6(b) Estimating Respondent Costs 

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

approximately $29.2 million over the 3 years covered by this information collection. Exhibit 6.1 

presents aggregate costs and costs by subpart W industry segment. For details of the EPA’s cost 

calculations, please see Appendix C and Appendix D. The proposed information collection will 

result in an overall increase in annual burden of 73,000 hours and $7.2 million. This increase is 

split between the three subpart W industry segments as shown in Exhibit 6.2. 

(i) Estimating Labor Costs. Costs to respondents associated with this information 

collection include the cost of labor by facility staff to meet the rule’s information collection 

requirements. To calculate labor costs, the EPA used labor rates from the Bureau of Labor 
Page 15 November 2014 

Statistics consistent with the ICRs associated with the GHGRP currently approved by OMB.1 For 

all subpart W industry segments, the labor rate derivations are shown in Table 2. The labor rates 

for this ICR are: $121.72 for senior managers, $106.89 for middle managers, $78.29 for engineers, 

and $66.57 for technicians. 

Table 2. Labor Rate Derivations 

Labor 

Category 

Wage and 

Salariesa

BLS 

Occupational 

Code 

Benefits 

Loading 

Factorb

Overhead 

Loading Factorc

Loaded Labor 

Rate (2011$)d

Engineer $50.84 17-2112 0.3699 0.17 $78.29

Technician $43.23 17-3024 0.3699 0.17 $66.57

Middle manager $64.12 11-3051 0.4970 0.17 $106.89

Senior manager $73.02 11-1021 0.4970 0.17 $121.72

a

 The base hourly wages & salaries (not including benefits & overhead) are from BLS's May 2011 National Industry 

Specific Occupational Employment and Wage Estimates (http://www.bls.gov/oes/2011/may/oessrci.htm#22). 

b

 From BLS's ECEC (http://www.bls.gov/ect/home.htm) for June of 2006 (see archive at 

http://www.bls.gov/news.release/archives/ecec_09222006.pdf). 

c

 The overhead loading factor is from Rice, Cody 2002. "Wage Rates for Economic Analyses of the Toxics Release 

Inventory Program,” Analytical Support Branch, Environmental Analysis Division, Office of Environmental 

Information, U.S. EPA, June 10, 2002. 

d

 The loaded hourly rate = Wages & Salaries + (Wages & Salaries x Benefits Loading Factor) + (Wages & Salaries * 

Overhead Loading Factor). The benefits loading factor and overhead loading factor reflect the factors used in the 2009 

and 2010 ICRs. 

Burden estimates were calculated by assigning a level of effort for each new requirement in 

the rule, assigning each requirement to one or more of the labor categories above, estimating the 

number of units affected by each new requirement, determining how many reporters will be 

impacted under each segment, and multiplying by the appropriate labor rates. 

In order to be consistent with the levels of effort used for the existing industry segments, all 

levels of effort were estimated using the Economic Impact Analysis from November 2010.2

For details of the burden calculations, please see Appendix B. 

(ii) Estimating Capital and Operations and Maintenance (O&M) Costs Related to Process 

Emissions. The amendments to subpart W assume that various capital and O&M costs will be 

 

1

 May 2011 National Industry-Specific Occupational Employment and Wage Estimates 

(http://www.bls.gov/oes/2011/may/oessrci.htm) and Employer Costs for Employee Compensation for June of 2011 

(http://www.bls.gov/news.release/archives/ecec_09082011.pdf). 

2

Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions Under Subpart W Final

Rule (GHG Reporting); Final Report, U.S. Environmental Protection Agency Office of Atmospheric Programs. 

Climate Change Division. November 2010. Docket Item No. EPA-HQ-OAR-2009-0923-3601. Pages 4-23 through 

4-28.
Page 16 November 2014 

required to comply with the monitoring, recordkeeping, and reporting of process emissions within 

this proposed rule. 

Each new reporter was assumed to require a 4-drawer vertical file cabinet and an external 

hard drive for storing various records and electronic data. The annualized capital cost for each 

reporter is $57 per year for a total of $22,800 per year.3

During oil well completions and workovers with hydraulic fracturing, there is a flowback 

period where the gas flow rate is monitored using a volumetric flow meter. These requirements 

affect approximately 50 new and 246 existing reporters in the Onshore Petroleum and Natural Gas 

Production industry segment. These reporters are assumed to purchase a volumetric flow meter at 

a cost of $585 per year ($2,400 annualized over 5 years at 7% interest).4

 The total cost is 

approximately $173,000 per year. 

The final capital and O&M cost impacts are related to travel costs. For Onshore Petroleum 

and Natural Gas Gathering and Boosting facilities, the size of a facility was assumed to encompass 

a much larger geographic area than a relatively compact producing field or a gas processing plant. 

In order to account for emissions measurement across a larger area, travel costs were included and 

assumed to consist of 14 overnight trips per reporter per year. Assuming $150 per night and $100 

per diem,5

 a cost of $3,500 per reporter per year was assumed. The total annual cost for travel is 

$700,000 per year. 

Due to the fact that compressor stations are unmanned, pipeline throughput is continuously 

monitored and controlled and the engineering data would be readily available to the reporters in 

the Onshore Natural Gas Transmission Pipeline segment. Therefore, reporters are assumed to 

perform engineering calculations based on pressure, temperature, and volume of the pipeline 

segment rather than traveling to the compressor stations to take measurements. 

The addition of oil well completions and workovers with hydraulic fracturing is not 

expected to impact any amount of travel that may be required of reporters in the Onshore 

Petroleum and Natural Gas Production segment. 

 

3

Ibid. Page 4-29. 

4

 Based on an average cost of five volumetric gas flow meters from Omega Engineering, FLO-CORP, Sierra 

Instruments, and Instrumart. 

5

Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions Under Subpart W Final

Rule (GHG Reporting); Final Report, U.S. Environmental Protection Agency Office of Atmospheric Programs. 

Climate Change Division. November 2010. Docket Item No. EPA-HQ-OAR-2009-0923-3601. Page 4-29. 
Page 17 November 2014 

(iii) Estimating Capital and O&M Costs Related to Combustion Emissions. The 

amendments to subpart W that are included in this information collection affect the 

combustion-related capital and O&M costs for the Onshore Petroleum and Natural Gas Gathering 

and Boosting industry segment. For all other segments, the capital and O&M costs have not 

changed from ICR Number 2300.15. 

For the Onshore Petroleum and Natural Gas Gathering and Boosting and Onshore 

Petroleum and Natural Gas Production segments, the capital and O&M costs associated with 

combustion emissions were based on the assumptions in ICR Number 2376.02, which included 

capital equipment costs of $3,500 (annualized over 10 years at 7% interest to $500 per year) and 

O&M costs of $1,700 per year.6

There are no combustion sources at Onshore Natural Gas Transmission Pipeline facilities, 

so there are no increases to capital and O&M costs as a result of the subpart W amendments. 

 

6

Ibid. Page 4-11 
Page 18 November 2

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

Subpart W

Industry Segment 

No. 

Respondents Total Responses Burden– Engineer (hrs) Burden - Technician (hrs) Burden – Middle Manager (hrs) Burden – Senior Manager (hrs) Total Burden (hrs) Total Labor Cost ($) Capital Cost ($) 

Onshore Natural Gas Transmission Pipelines 

150 150 5,190 0 375 188 5,753 $469,231 $8,597 

Onshore Petroleum and Natural Gas Gathering and Boosting 

200 200 8,187 360 500 250 9,297 $748,774 $111,064 

Onshore Natural Gas Processing 291 398 13,844 8,948 3,082 204 26,078 $2,035,807 $232,860 Onshore Natural Gas Transmission Compression 

1,152 1,501 70,734 0 7,128 0 77,862 $5,943,128 $397,539 

Underground Natural Gas Storage 139 224 10,583 0 2,107 0 12,690 $1,003,059 $65,803 LNG Import and Export Equipment 4 4 330 0 43 0 373 $29,496 $2,400 Onshore Petroleum and Natural Gas Production 

1,083 2,166 138,701 236 20,934 63 159,934 $13,142,142 $260,116 

Natural Gas Distribution 159 159 17,862 0 1,247 0 19,109 $1,390,860 $23,267 LNG Storage 35 70 2,379 0 649 0 3,029 $250,085 $14,883 Offshore Petroleum and Natural Gas Production 

72 130 2,153 0 1,074 0 3,227 $285,779 $0 

TOTAL 3,285 5,002 269,964 9,544 37,140 704 317,352 $25,298,361 $1,116,529 
Page 19 November 2

Exhibit 6.2 Annual Average Change in Respondent Burden and Cost For Subpart W of the GHGRP 

Subpart W Industry Segment 

Change In Total Burden 

(Technical Labor Hours) 

Change in Burden 

(Technical Labor 

Hours/Respondent) 

Change In 

Cost 

($) 

Onshore Natural Gas Transmission Pipelines a 5,753 38.35 $477,82Onshore Petroleum and Natural Gas Gathering and Boosting b 9,297 46.48 $1,899,8Onshore Natural Gas Processing c 0 0.00 $0 Onshore Natural Gas Transmission Compression d 0 0.00 $0 Underground Natural Gas Storage e 0 0.00 $0 LNG Import and Export Equipment f 0 0.00 $0 Onshore Petroleum and Natural Gas Production g 57,963 53.52 $4,827,3Natural Gas Distribution h 0 0.00 $0 LNG Storage i 0 0.00 $0 Offshore Petroleum and Natural Gas Production j 0 0.00 $0 TOTAL 73,012 --- $7,205,0a For Onshore Natural Gas Transmission Pipelines, the technical labor hour burden increased from 0 hours to 5,753 hours, which increased the total cb For Onshore Petroleum and Natural Gas Gathering and Boosting, the technical labor hour burden increased from 0 hours to 9,297 hours, which incre

$1,899,839. 

c For Onshore Natural Gas Processing, the technical labor hour burden and costs remained the same. d For Onshore Natural Gas Transmission Compression, the technical labor hour burden and costs remained the same. e For Underground Natural Gas Storage, the technical labor hour burden and costs remained the same. f For LNG Import and Export Equipment, the technical labor hour burden and costs remained the same. g For Onshore Petroleum and Natural Gas Production, the technical labor hour burden increased from 101,924 hours to 159,888 hours, which increased 

to $13,487,258. 

h For Natural Gas Distribution, the technical labor hour burden and costs remained the same.
Page 20 November 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 

The 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. The EPA estimates that, in implementing the two new industry 

segments under subpart W, Headquarters will incur an incremental burden of 1 full time equivalent 

(FTE). The total Agency cost is $544,648, which is $109,000 higher than the previous ICR 

estimate of $436,000. 

To develop the EPA labor costs, the EPA estimates the average hourly labor rate for salary 

and overhead and benefits for Agency staff to be $52.37. To derive this figure, the 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. 

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 ($) 

Information Collection 

Activity 

Annual 

Responses 

Total Annual 

Burden Labor Cost Non-Labor Cost 

Total Annual 

Cost 

W. Petroleum and 

Natural Gas Systems 1 10,400 $544,648 $0 $544,648 

TOTAL 1 10,400 $544,648 $0 $544,648 
Page 21 November 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/Master Tables 

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 3,285 From Exhibit 6.1 

Total Annual Responses 5,002 From Exhibit 6.1 

Number of Responses per 

Respondent 1.5 Total annual responses from above ÷ Total respondents from above 

Total Respondent Hours 317,352 From Exhibit 6.1 

Hours per Response 63.4 Total annual hours from above ÷ Total respondents from above 

Annual O&M and Capital 

Cost 3,931,483 From Exhibit 6.1 

Total Respondent Cost 

(labor + non) 29,229,844 From Exhibit 6.1 

Total Hours (Respondents 

and Agency) 327,752 Total respondent hours from above + Total EPA hours 

Total Cost (Respondents 

and Agency) 29,774,492 Total respondent cost from above + Total EPA costs 

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 73,000 hours and 

$7.2 million. Specific respondent activities that impose an increase in burden and costs due to the 

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 232 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. 

Oil Wells with Hydraulic Fracturing. The EPA is proposing to add reporting requirements 

for completions and workovers of oil wells with hydraulic fracturing. The proposed provisions 
Page 22 November 2014 

include the reporting of activity data on the number of wells fractured and on the use of flaring and 

reduced emissions completions. This proposed revision is an increase in burden and cost to the 

estimated 50 new reporters and 246 existing reporters containing oil wells with hydraulic 

fracturing, who would be reporting data elements that were not previously required. 

Onshore Petroleum and Natural Gas Gathering and Boosting. The EPA is proposing to add 

a new Onshore Petroleum and Natural Gas Gathering and Boosting segment to subpart W. The 

proposed requirements would require the reporting of GHG emissions from an entire gathering 

and boosting facility instead of the partial approach that currently exists under the GHGRP. 

Specifically, some gathering and boosting emission sources, such as natural gas compression 

stations, are only required to report GHG emissions if the facility exceeds the 25,000 metric tons 

CO2e annual emission reporting threshold in subpart A, 40 CFR 98.2(a)(2), based on combustion 

emissions that are reported under subpart C. Subpart W does currently require reporting from 

facilities that perform “natural gas processing” in 40 CFR 98.230(a)(3), but this requirement is 

only for those facilities that perform separation of natural gas liquids or non-methane gases from 

produced natural gas or the separation of natural gas liquids into one or more component mixtures 

and exceed 25 million standard cubic feet per day annual average daily gas throughput 

Due to these proposed changes, the sources in this segment would include venting from 

natural gas pneumatic devices, natural gas driven pneumatic pumps, storage tanks, reciprocating 

compressors, dehydrators, acid gas removal units, and centrifugal compressors; flare stacks; and 

leaks from gathering pipelines and components such as valves and connectors. Approximately 200 

new reporters in this industry segment would need to collect data, calculate, and report these 

emissions under the proposed revisions. This proposed revision is an increase to burden and cost. 

Natural Gas Transmission Lines Between Compressor Stations. The EPA is proposing to 

add reporting requirements for emissions from blowdowns of natural gas transmission pipelines in 

a new Onshore Natural Gas Transmission Pipeline segment in subpart W. The EPA is proposing 

that reporters would use one of two methods to calculate or measure emissions from pipeline 

blowdown events. One method allows a reporter to calculate emissions based on the volume of the 

pipeline segment between isolation valves that is blown down and the pressure and temperature of 

the gas within the pipeline. The second method allows the reporter to measure the emissions from 

the blowdown using a flow meter on the blowdown vent stack. In both methods, approximately 
Page 23 November 2014 

150 new reporters would calculate both CH4 and CO2 emissions from the volume of natural gas 

vented using either default gas composition or engineering estimates of composition. This 

proposed revision is an increase to burden and cost. 

Well Identification Numbers. The EPA is proposing to add reporting requirements for well 

identification numbers for wells in the onshore petroleum and natural gas production. The well 

identification number is either the US Well Number (formerly called the API Well Number), or if 

a US Well Number has not been assigned, a unique number assigned by the permitting authority. 

These numbers are readily available and do not require any additional data gathering or 

calculation. The small additional burden needed to report the numbers in e-GGRT is included in 

the overall reporting burden estimate of 10 hours per reporter per year. 

6(g) Burden Statement 

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

317,400 hours and $29.2 million per year for a three-year period, where identical annual costs are 

anticipated for all three years. The average annual burden to the EPA for this period is estimated to 

be 10,400 hours for oversight activities. The annual public reporting and recordkeeping burden for 

this collection of information is estimated to average 63.4 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 the 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 
Page 24 November 2014 

use of automated collection techniques, the EPA has established a public docket for this ICR 

under Docket ID No. EPA–HQ–OAR–2014-0831, 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 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-2014-0831 and OMB Control Number 2060-0629 on any correspondence. 

Part B of the Supporting Statement 

This section is not applicable because statistical methods are not used in data collection 

associated with the proposed amendments.