MEMORANDUM –PROPOSED CHANGES TO SUBPART W INPUTS 

To: Docket EPA-HQ-OAR-2011-0028 

From: Lisa Bacanskas, EPA/Climate Change 

Date: January 26, 2012 

Subject: Proposed changes to Table A-7 in subpart A of 40 CFR part 98. 

In this memorandum, we show the proposed changes to Table A-7 in subpart A of 40 

CFR part 98 since amended by the Final Deferral (76 FR 53057, August 25, 2011). These 

changes to Table A-7 are proposed in the Proposed Confidentiality Determinations and 

Corrections to the Petroleum and Natural Gas Systems Source Category, and Amendments to 

Table A-7, of the Greenhouse Gas Reporting Rule (referred to hereinafter as the “Proposed 

Subpart W CBI Rule”). Table 1 shows the proposed deletions from Table A-7 with red strike-out 

text and shows the proposed additions to Table A-7 with red text in a green background. 

Table 1. Proposed Changes to Table A-7 in subpart A of Part 98.

a 

Subpart Rule Citation (40 CFR part 98)

Specific Data Elements for 

Which Reporting Date is March 

31, 2015 (“All” means all 

data elements in the cited 

paragraph are not required to 

be reported until March 31, 

2015)

* * * * * * * 

W 98.236(c)(1)(i) All. 

W 98.236(c)(1)(ii) All. 

W 98.236(c)(1)(iii) All. 

W 98.236(c)(2)(i) All. 

W 98.236(c)(3)(i) All. 

W 98.236(c)(3)(ii) All. Only Calculation 

Methodology 2. 

W 98.236(c)(3)(iii) All. 

W 98.236(c)(3)(iv) All. 

W 98.236(c)(4)(i)(A) All. 

W 98.236(c)(4)(i)(B) All. 
Subpart Rule Citation (40 CFR part 98)

Specific Data Elements for 

Which Reporting Date is March 

31, 2015 (“All” means all 

data elements in the cited 

paragraph are not required to 

be reported until March 31, 

2015)

W 98.236(c)(4)(i)(C) All. 

W 98.236(c)(4)(i)(D) All. 

W 98.236(c)(4)(i)(E) All. 

W 98.236(c)(4)(i)(F) All. 

W 98.236(c)(4)(i)(G) All. 

W 98.236(c)(4)(i)(H) All. 

W 98.236(c)(4)(ii)(A) All. 

W 98.236(c)(5)(i)(D) All. 

W 98.236(c)(5)(ii)(C) All. 

W 98.236(c)(5)(iii) All.

W 98.236(c)(5)(iv) All.

W 98.236(c)(5)(v) All.

W 98.236(c)(6)(i)(B) All. 

W 98.236(c)(6)(i)(D) All. 

W 98.236(c)(6)(i)(E) All. 

W 98.236(c)(6)(i)(F) All. 

W 98.236(c)(6)(i)(G) Only the amount of natural 

gas required. 

W 98.236(c)(6)(i)(H) Only the amount of natural 

gas required. 

W 98.236(c)(6)(ii)(A) All. 

W 98.236(c)(6)(ii)(B) All. 

W 98.236(c)(7)(i) All.

W 98.236(c)(7)(i)(A) Only for Equation W-14A. 

W 98.236(c)(8)(i)(B) All.

W 98.236(c)(8)(i)(C) All.

W 98.236(c)(8)(i)(F) All. 

W 98.236(c)(8)(i)(K) All. 

W 98.236(c)(8)(ii)(A) All. 

W 98.236(c)(8)(ii)(D) All.

W 98.236(c)(8)(ii)(H) All. 

W 98.236(c)(8)(iii)(A) All. 

W 98.236(c)(8)(iii)(B) All. 

W 98.236(c)(8)(iii)(D) All.
Subpart Rule Citation (40 CFR part 98)

Specific Data Elements for 

Which Reporting Date is March 

31, 2015 (“All” means all 

data elements in the cited 

paragraph are not required to 

be reported until March 31, 

2015)

W 98.236(c)(8)(iii)(E) All.

W 98.236(c)(8)(iii)(G) All. 

W 98.236(c)(10)(ii) All.

W 98.236(c)(10)(iii) All.

W 98.236(c)(11)(ii) All.

W 98.236(c)(12)(ii) All. 

W 98.236(c)(12)(iii) All.

W 98.236(c)(12)(v) All. 

W 98.236(c)(13)(i)(B) All.

W 98.236(c)(13)(i)(E) All. 

W 98.236(c)(13)(i)(F) All. 

W 98.236(c)(13)(ii)(A) All. 

W 98.236(c)(13)(ii)(B) All. 

W 98.236(c)(13)(iii)(A) All. 

W 98.236(c)(13)(iii)(B) All. 

W 98.236(c)(13)(v)(A) All. 

W 98.236(c)(14)(i)(B) All. 

W 98.236(c)(14)(ii)(A) All. 

W 98.236(c)(14)(ii)(B) All. 

W 98.236(c)(14)(iii)(A) All. 

W 98.236(c)(14)(iii)(B) All. 

W 98.236(c)(14)(v)(A) All. 

W 98.236(c)(15)(i)(A) All.

W 98.236(c)(15)(i)(B) All.

W 98.236(c)(15)(ii)(A) All. 

W 98.236(c)(15)(ii)(B) All. 

W 98.236(c)(16)(i) All.

W 98.236(c)(16)(ii) All.

W 98.236(c)(16)(iii) All.

W 98.236(c)(16)(iv) All.

W 98.236(c)(16)(v) All.

W 98.236(c)(16)(vi) All.

W 98.236(c)(16)(vii) All.
Subpart Rule Citation (40 CFR part 98)

Specific Data Elements for 

Which Reporting Date is March 

31, 2015 (“All” means all 

data elements in the cited 

paragraph are not required to 

be reported until March 31, 

2015)

W 98.236(c)(16)(viii) All. 

W 98.236(c)(16)(ix) All. 

W 98.236(c)(16)(x) All. 

W 98.236(c)(16)(xi) All. 

W 98.236(c)(16)(xii) All. 

W 98.236(c)(16)(xiii) All. 

W 98.236(c)(16)(xiv) All. 

W 98.236(c)(16)(xv) All. 

W 98.236(c)(16)(xvi) All. 

W 98.236(c)(17)(ii) All. 

W 98.236(c)(17)(iii) All. 

W 98.236(c)(17)(iv) All. 

W 98.236(c)(18)(i) All. 

W 98.236(c)(18)(ii) All. 

W 98.236(c)(19)(iv) All. 

W 98.236(c)(19)(vii) All. 

* * * * * * * 

a Notes about this table: These proposed deletions and additions to this table primarily result from changes to subpart 

W data elements as finalized in the [Final] Mandatory Reporting of Greenhouse Gases: Technical Revisions to the 

Petroleum and Natural Gas Systems Category of the Greenhouse Gas Reporting [Rule] (hereinafter referred to as 

the “Subpart W Technical Revisions final rule”; 76 FR 80554, December 23, 2011). Some of these changes are the 

result of new or removed data elements in the Subpart W Technical Revisions final rule; however, many other data

elements were re-numerated in the Subpart W Technical Revisions final rule and accordingly correspond to an 

addition (red text in a green cell), deletion (red strike-out text), or combination of the two in the table above. The 

following changes to the above table correspond to the re-numerated data elements in the Subpart W Technical 

Revisions final rule: 

• 40 CFR 98.236(c)(5)(iii) (strike-out deletion) was re-numerated to 98.236(c)(5)(ii)(C) (red text additions), 

• 40 CFR 98.236(c)(5)(iv) (strike-out deletion) was re-numerated to 98.236(c)(5)(i)(D) (red text addition), 

• 40 CFR 98.236(c)(16)(iii) (strike-out deletion) was re-numerated to 98.236(c)(16)(viii) and 

98.236(c)(16)(iii) was replaced by a new non-input, 

• 40 CFR 98.236(c)(16)(vii) (strike-out deletion) was re-numerated to 98.236(c)(16)(ix) and 

98.236(c)(16)(vii) was replaced by a “reserved” placeholder, 

• 40 CFR 98.236(c)(16)(xiii) was re-numerated to 98.236(c)(16)(xv) (red text addition) and 

98.236(c)(16)(xiii) was replaced by another re-numerated input, and 

• 40 CFR 98.236(c)(16)(xiv) was re-numerated to 98.236(c)(16)(xvi) (red text addition) and 

98.236(c)(16)(xiv) was replaced by another re-numerated input. 
As shown in Table 1, a number of rule citations are proposed to be removed from Table 

A-7 in subpart A of 40 CFR part 98 (see 76 FR 53057, August 25, 2012). Table 2 shows the 

justifications for proposing to remove these rule citations from Table A-7. As noted in the 

preamble to the Proposed Subpart W CBI Rule, these proposed deletions are either the result of 

changes to the underlying subpart W reporting requirements made by the Subpart W Technical 

Revisions final rule (e.g., data elements for which the citations were changed) or the result of the 

proposed re-assignment of data elements from the inputs data category to another data category 

in situations where the underlying data element(s) no longer meet the definition of inputs to 

emission equations provided in the July 7, 2010 CBI Proposal (see 75 FR 39094) (e.g., 40 CFR 

98.236(c)(11)(ii) is proposed to be deleted from Table A-7 because the corresponding data 

element was revised in the Subpart W Technical Revisions final rule to be the average gas-to-oil 

ratio instead of the actual gas-to-oil ratios that are used as inputs to Equation W-18). 

Table 2. Justification for moving data elements out of Table A-7 in subpart A of Part 98.a

Rule Citation (40 

CFR part 98) 

Specific 

Data 

Element 

Justification for Proposed Removal from 

Table A-7 

98.236(c)(3)(ii) Only 

Calculation 

Methodology 

1. 

Data element is not used as an input to 

Equation W-3 for Calculation Methodology 

1 (only for Calculation Methodology 2). 

98.236(c)(5)(iii) All. Re-numerated to 40 CFR 

98.326(c)(5)(ii)(C) by the Subpart W 

Technical Revisions final rule. This data 

element is proposed to remain in Table A7 under this new citation. 

98.236(c)(5)(iv) All. Re-numerated to 40 CFR 98.326(c)(5)(i)(D) 

by the Subpart W Technical Revisions 

final rule. This data element is proposed 

to remain in Table A-7 under this new 

citation. 

98.236(c)(5)(v) All. Re-numerated to 40 CFR 98.326(c)(5)(i)(E) 

by the Subpart W Technical Revisions 

final rule. This data element is proposed 

to move out of the input data category 

because the casing or tubing diameter are 

not used as inputs to Equation W-7. 
Rule Citation (40 

CFR part 98) 

Specific 

Data 

Element 

Justification for Proposed Removal from 

Table A-7 

98.236(c)(7)(i) All. This data element and citation were 

removed by the Subpart W Technical 

Revisions final rule. This was replaced 

with a new data element (40 CFR 

98.236(c)(7)(i)(A)) by the Subpart W 

Technical Revisions final rule and is 

proposed to be added to Table A-7. 

98.236(c)(8)(i)(B) All. Data reporting element was slightly 

revised in the Subpart W Technical 

Revisions final rule and is not used as 

an input to any emission equations. 

98.236(c)(8)(i)(C) All. Data reporting element was slightly 

revised in the Subpart W Technical 

Revisions final rule and is not used as 

an input to any emission equations. 

98.236(c)(8)(ii)(D) All. Data reporting element was slightly 

revised in the Subpart W Technical 

Revisions final rule and is not used as 

an input to any emission equations. 

98.236(c)(8)(iii)(D) All. Data reporting element was slightly 

revised in the Subpart W Technical 

Revisions final rule and is not an input 

to Equation W-15. 

98.236(c)(8)(iii)(E) All. Data reporting element was slightly 

revised in the Subpart W Technical 

Revisions final rule and is not an input 

to Equation W-15. 

98.236(c)(10)(ii) All. Data reporting element was slightly 

revised in the Subpart W Technical 

Revisions final rule. The data reporting 

element specifies the average gas-to-oil 

ratio for each basin while the specific 

gas-to-oil ratio for each well in a basin 

is specified in Equation W-17A. 

98.236(c)(10)(iii) All. Data reporting element was slightly 

revised in the Subpart W Technical 

Revisions final rule. The data reporting 

element specifies the average number of 

days the well is tested in a basin which 

is not specified in Equation W-17B. 

98.236(c)(11)(ii) All. Data reporting element was slightly 

revised in the Subpart W Technical 

Revisions final rule. The data reporting 

element specifies the average gas-to-oil 

ratio for each basin while the specific 

gas-to-oil ratio for each well in a basin 

is specified in Equation W-18. 

98.236(c)(12)(iii) All. Data reporting element was revised in the 

Subpart W Technical Revisions final rule 

and is no longer an input to Equation W18. 
Rule Citation (40 

CFR part 98) 

Specific 

Data 

Element 

Justification for Proposed Removal from 

Table A-7 

98.236(c)(13)(i)(B) All. The fraction of operating time specified 

in Equation W-22 is not the same as the 

fraction of vent gas recovered specified 

in this data reporting requirement. 

98.236(c)(15)(i)(A) All. The actual count of leaks as specified in 

this data reporting requirement is not an 

input to Equation W-30A or W-30B. The 

calculation is performed as the sum over 

all leaking equipment components. 

98.236(c)(15)(i)(B) All. Data reporting element was revised in 

Subpart W Technical Revisions final rule 

to “range of concentrations” and Equation 

W-30 specifies actual concentration; 

thus, this is no longer an input to 

Equation W-30 

98.236(c)(16)(i) All. Replaced in the Subpart W Technical 

Revisions final rule by a new data 

reporting requirement that is not an 

input to any emission equations. 

98.236(c)(16)(ii) All. Replaced in the Subpart W Technical 

Revisions final rule by a new data 

reporting requirement that is not an 

input to any emission equations. 

98.236(c)(16)(iii) All. Re-numerated to 40 CFR 

98.236(c)(16)(viii) and replaced in the 

Subpart W Technical Revisions final rule 

by a new data reporting requirement that 

is not an input to emission equation. 

This data element is proposed to remain 

in Table A-7 under this new citation. 

98.236(c)(16)(iv) All. Replaced in the Subpart W Technical 

Revisions final rule by a new data 

reporting requirement that is not an 

input to any emission equations. 

98.236(c)(16)(v) All. Replaced in the Subpart W Technical 

Revisions final rule by a new data 

reporting requirement that is not an 

input to any emission equations. 

98.236(c)(16)(vi) All. Replaced in the Subpart W Technical 

Revisions final rule by a new data 

reporting requirement that is not an 

input to any emission equations. 

98.236(c)(16)(vii) All. Data element was re-numerated to 40 CFR 

98.326(c)(16)(ix) by the Subpart W 

Technical Revisions final rule and 

replaced with a “Reserved” placeholder. 

a Notes about this table: This table includes four data elements that were re-numerated by the Subpart W Technical 

Revisions final rule (40 CFR 98.326(c)(5)(iii), (5)(iv), (16)(iii), and (16)(vii) that remain in Table A-7 under a 

different citation. The remaining 21 data elements, which include 20 rule citations (40 CFR 98.326(c)(8)(i)(B) was 

split into two data reporting elements for Calculation Methodologies 1 and 2), are proposed to be re-assigned to 

other data categories in the preamble to the Proposed Subpart W CBI Rule.