SUPPORTING STATEMENT PART A:

INFORMATION COLLECTION REQUEST

FOR THE

GREENHOUSE GAS REPORTING PROGRAM

EPA ICR No. 2300.17

October 2015
TABLE OF CONTENTS

1. IDENTIFICATION OF THE INFORMATION COLLECTION.................................... 1

1(a) Title of the Information Collection................................................................................. 1

1(b) Short Characterization/Abstract ..................................................................................... 1

2. NEED FOR AND USE OF THE COLLECTION........................................................... 3

2(a) Need/Authority for the Collection.................................................................................. 3

2(b) Practical Utility/Users of the Data ................................................................................. 3

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA ...................................................................................................................................... 6

3(a) Nonduplication ............................................................................................................... 6

3(b) Public Notice Required Prior to Information Collection Request (ICR) Submissions to 

OMB ................................................................................................................................ 8

3(c) Consultations.................................................................................................................. 8

3(d) Effects of Less Frequent Collection............................................................................... 9

3(e) General Guidelines....................................................................................................... 10

3(f) Confidentiality .............................................................................................................. 10

3(g) Sensitive Questions...................................................................................................... 10

4. THE RESPONDENTS AND THE INFORMATION REQUESTED........................... 11

4(a) Respondents/North American Industrial Classification Systems (NAICS) Codes...... 11

4(b) Information Requested ................................................................................................. 14

5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION 

METHODS, AND INFORMATION MANAGEMENT.............................................................. 16

5(a) Agency Activities......................................................................................................... 16

5(b) Collection Methodology and Management.................................................................. 16

5(c) Small Entity Flexibility ................................................................................................ 16

5(d) Collection Schedule...................................................................................................... 17

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION....................... 18

6(a) Estimating Respondent Burden .................................................................................... 18

6(b) Estimating Respondent Costs....................................................................................... 18

6(c) Estimating Agency Burden and Cost ........................................................................... 25

6(d) Estimating the Respondent Universe and Total Burden and Costs.............................. 26

6(e) Bottom Line Burden Hours and Costs.......................................................................... 26

6(f) Reasons for Change in Burden..................................................................................... 27

6(g) Burden Statement ......................................................................................................... 28
LIST OF APPENDICES

A. Current Information Collection Requests Associated with the Greenhouse Gas Reporting Program

B. Greenhouse Gas Reporting Program: Reporting Thresholds and Reporting Requirements 

C. Greenhouse Gas Reporting Program: Recordkeeping Requirements 

D. Summary of Labor Rate Derivation

E. Burden and Cost for Petroleum and Natural Gas Systems (Subpart W)

E-1. Detailed Unit Burden and Costs for Petroleum and Natural Gas Systems (Subpart W)—

Year 1

E-2. Detailed Unit Burden and Costs for Petroleum and Natural Gas Systems (Subpart W)—

Year 2 

E-3. Detailed Unit Burden and Costs for Petroleum and Natural Gas Systems (Subpart W)—

Year 3 

E-4. Footnotes Applicable to Appendices E-1, E-2, and E-3

E-5 Summary of Burden and Costs for Petroleum and Natural Gas Systems (Subpart W) by 

Industry Segment and Year

F. Burden and Cost Estimate for Injection and Geologic Storage of Carbon Dioxide (Subpart RR)
ICR for the GHGRP Page 1 August 2015

SUPPORTING STATEMENT

FOR THE GREENHOUSE GAS REPORTING PROGRAM 

EPA ICR # 2300.17

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection

TITLE: “Information Collection Request for the Greenhouse Gas Reporting Program

(GHGRP).”

ICR Number: 2300.17

1(b) Short Characterization/Abstract

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

110-161) and under authority of the Clean Air Act (CAA), EPA finalized a greenhouse gas 

reporting rule in October of 2009 (henceforth referred to as the Greenhouse Gas Reporting 

Program or GHGRP) (74 FR 56260; October 30, 2009). The Rule, which became effective on 

December 29, 2009, requires reporting of greenhouse gases (GHGs) from certain large facilities 

and suppliers. It does not require control of greenhouse gases. Instead, it requires that sources 

emitting or supplying above certain threshold levels of carbon dioxide (CO2) equivalent (CO2e) 

monitor and report GHG data and other relevant information. Subsequent rules have 

promulgated requirements for additional facilities, suppliers, and mobile sources; provided 

clarification and corrections to existing requirements; finalized confidentiality business 

information (CBI) determinations, amended recordkeeping requirements, and implemented an 

alternative verification approach.

Applicable facilities and suppliers are required by the GHGRP to follow specific 

monitoring, QA/QC, and calculation procedures to determine GHG emissions and supplies to the 

economy. Reporters must electronically report monitored and calculated data to EPA using an 

interactive, web-based tool called the electronic greenhouse gas reporting tool (e-GGRT). EPA 

conducts electronic and manual verification of the reported data and then publishes all non-CBI 

data on the internet. For 23 subparts, some data used to calculate GHG emissions are not 

reported to EPA because of disclosure concerns. Reporters instead enter those data into a webbased verification tool (Inputs Verifier Tool (IVT)) housed within e-GGRT. IVT does not retain 

the entered inputs; instead it calculates emissions using entered “inputs to equations” and 

conducts verification checks at the time of data entry. IVT generates a verification summary that 

is accessible to the EPA once the annual report is submitted.

The Office of Management and Budget’s (OMB’s) approval of the original Information 

Collection Request (ICR) for the GHG Reporting Rule expired on November 10, 2012. A 

renewal was approved for three years and will expire on May 31, 2016. Since the renewal was 

approved, seven amendments to the GHGRP have been finalized and have included incremental 
ICR for the GHGRP Page 2 August 2015

updates to the ICR. The purpose for this ICR is to renew and revise the GHG Reporting Rule

ICR. Appendix A summarizes the ICRs associated with the GHGRP. 

There is a decrease of 102,121 hours and an increase of $11.0 million in the total 

estimated respondent burden compared with that identified in the last ICR renewal. This change 

in burden reflects an adjustment in the number of respondents from projected to actual, an 

adjustment of labor rates and capital costs to reflect 2013 dollars, a re-evaluation of the activities 

and costs associated with Subparts W and RR, and the addition of new segments and new 

reporters under Subpart W. 
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2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

Signed into law on December 26, 2007, the FY2008 Consolidated Appropriations Act

(henceforth referred to as the “Appropriations Act”) 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.” 

The accompanying explanatory statement further directed EPA to “use its existing 

authority under the Clean Air Act” (CAA) to develop a GHG reporting rule. “The Agency is 

further directed to include in its rule reporting of emissions resulting from upstream production 

and downstream sources, to the extent that the Administrator deems it appropriate. The 

Administrator shall determine appropriate thresholds of emissions above which reporting is 

required, and how frequently reports shall be submitted to EPA. The Administrator shall have 

discretion to use existing reporting requirements for electric generating units under Section 821”

of the 1990 CAA amendments.

Sections 114 and 208 of the Clean Air Act (CAA) provide EPA authority to require the 

information mandated by the Greenhouse Gas Reporting Program (GHGRP) because such data 

will inform and are relevant to future policy decisions. 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 monitor and report emissions and 

provide such other information the Administrator requests for the purposes of carrying out any 

provision of the CAA (except for a provision of title II with respect to manufacturers of new 

motor vehicles or new motor vehicle engines). Section 208 of the CAA provides EPA with 

similar authority regarding the manufacturers of new motor vehicles or new motor vehicle 

engines, and other persons subject to the requirements of parts A and C of title II. For these 

reasons, the Administrator may request that a person, on a one-time, periodic or continuous 

basis, establish and maintain records, make reports, install and operate monitoring equipment 

and, among other things, provide such information the Administrator may reasonably require.

2(b) Practical Utility/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. Reporting entities use 

uniform methods for estimating emissions, which enables data to be compared and analyzed. The 

comprehensive GHG data reported directly from large facilities and suppliers across the country 

are easily accessible to the public via EPA’s online data publication tool, also known as FLIGHT 

(facility level information on greenhouse gas tool) at: http://ghgdata.epa.gov/ghgp/main.do.

FLIGHT is designed for the general public, and allows users to view and sort GHG data for

every calendar year starting with 2010 from over 8,000 entities in a variety of ways, including by 

location, industrial sector, and type of GHG emitted. To support the needs of researchers, all 
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non-confidential data collected through the GHGRP is made available for download through 

Envirofacts (http://www.epa.gov/enviro/), a cross-EPA data publication website.

Data collected through the GHGRP complements the Inventory of U.S. Greenhouse Gas 

Emissions and Sinks (Inventory) and is currently being used to significantly improve our 

understanding of key emissions sources. In the most recent Inventory, published in April 2015, 

EPA used GHGRP data to update the entire emissions estimate and time series for six industries 

that are covered at no threshold in the GHGRP, including petroleum refineries and aluminum 

production. For an additional seven industries, EPA used GHGRP data to update portions of the 

Inventory emissions estimate, including with updates to emission factors and activity data. For 

example, EPA updated its Inventory estimates for hydraulically fractured natural gas well 

completions and workovers by using both emission rates and practice-specific activity data from 

the GHGRP. These data allow the Inventory to better reflect the impacts of recent regulations 

that are resulting in increases in control levels and decreases in methane emissions for this source 

category. Finally, EPA used GHGRP data to disaggregate some of the national estimates 

presented in the Inventory in order to show more detail and to quality check specific sectors, as 

appropriate. EPA continues to assess the GHGRP data for further updates to the Inventory.

The GHGRP has been used to support the President’s Climate Action Plan (CAP) in 

numerous ways. For example, the final carbon pollution standards for new power plants rely on 

rules that EPA already has in place, including under the Geologic Sequestration of Carbon 

Dioxide source category (subpart RR) of the GHGRP, to ensure that CO2 is safely and securely 

stored. Other actions that are a part of the CAP have also relied on GHGRP data. As part of the 

proposed New Source Performance Standard (79 FR 41796, July 17, 2014) and Emissions 

Guidelines (80 FR 52100, August 27, 2015) revisions for municipal solid waste landfills, a 

database was developed to calculate the cost and emission impacts associated with varying 

certain control parameters and applying these parameters to a dataset of existing and model 

future landfills. Information collected through Subpart HH of the GHGRP about the landfill itself 

(such as landfill open and closure year, landfill design capacity, landfill design area, and landfill 

depth), current and historical annual waste acceptance rates, as well as gas collection and control 

system data (as applicable) were incorporated into the database. These annual historical waste 

rate data serve as a significant improvement to the data input file used to generate emission 

estimates. Of the 1,970 landfills in the dataset, 1,217 were from GHGRP Subpart HH data. In 

addition, EPA will use the 2014 GHGRP data to support the effort to respond to comments on 

the proposal and prepare the final regulations, including an update to the cost and emission 

impacts documents as needed. As another example, as part of the Climate Action Plan: Strategy 

to Reduce Methane Emissions, the EPA released a series of white papers on several potentially 

significant sources of methane emissions in the oil and natural gas sector. The white papers 

included information, where applicable, from the Petroleum and Natural Gas Systems source 

category (Subpart W) of the GHGRP on sources such as compressors and pneumatic devices.

GHGRP data is also supporting the proposed Natural Gas STAR Methane Challenge Program, 

which proposes to leverage GHGRP reporting to track partner company activities related to their 

Methane Challenge commitments.

Several states also use GHGRP data to inform their own climate change policymaking. 

For example, the state of Hawaii is using GHGRP data to establish an emissions baseline for 
ICR for the GHGRP Page 5 August 2015

each facility subject to their GHG Reduction Plan and to assess whether facilities meet their 

targets in future years. In addition, to meet their requirements for reporting oil and gas activities 

in their state to EPA under the National Emissions Inventory, States without their own data 

collection programs can leverage GHGRP data collected from the Petroleum and Natural Gas 

Systems source category.

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 and track their GHG footprints, find cost- and 

fuel-saving 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.

In addition, transparent, public data on emissions allows for accountability of polluters to the 

public stakeholders who bear the cost of the pollution. This powerful data resource provides a 

critical tool for communities to identify nearby sources of GHGs and provide information to state 

and local governments. One example of this type of practical utility of GHGRP data was 

outlined in a recent paper on manufacturers and users of electrical transmission and distribution 

equipment (subparts DD and SS) authored by EPA staff and contractors (see Docket). The paper 

explains that fluorinated GHG emissions from these industries decreased significantly between 2011 

and 2013, and that possible explanations for these reductions include increased awareness by 

facilities of the magnitude of their emissions (both in absolute terms and relative to the emissions of 

similar facilities) and/or concerns regarding public perception of those emissions.

The GHGRP is not intended to be a survey and the respondents affected by the program

are not intended to be a statistical sample of a larger universe of entities. EPA does not intend to 

use the data collected under the GHGRP to characterize non-reporting entities or to draw 

statistical inferences about a larger population.
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3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION

CRITERIA

3(a) Nonduplication

EPA evaluated existing GHG programs and the GHG data currently available to 

determine whether this request duplicates other information collections. In developing the 

GHGRP, 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; and 

• 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. 

These are important programs that not only led the way in reporting of GHG emissions 

before the Federal Government acted but also assisted in quantifying the GHG reductions 

achieved by various policies. Many of these programs collect different or additional data as 

compared to the GHGRP. For example, state programs may establish lower thresholds for 

reporting, request information on areas not addressed in the GHGRP, or include different data 

elements to support 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, EPA has made significant 

efforts over the past several years to facilitate reporting in the event a single entity has to report 

both the federal and state level. For example, 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 EPA’s GHGRP. The product of the collaboration is referred to as 

California Electronic Greenhouse Gas Reporting Tool, or Cal e-GGRT.

Documentation of 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 the 

docket at EPA-HQ-OAR-2008-0508-056. For further discussion on the relationship of the 
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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 (which can be found in the 

docket at EPA-HQ-OAR-2008-0508-0052), and the January 27, 2009 memorandum entitled 

Review of Existing State Greenhouse Gas Reporting Rules (which can be found in the docket at 

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

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

programs.

• EPA considered CO2 data currently collected under Section 821 of the 1990 CAA 

Amendments. To avoid duplication and because the Acid Rain program already 

requires reporting of high quality CO2 data from electrical generating units (EGUs), 

the GHGRP allows for use of the same CO2 data rather than requiring additional 

reporting of CO2 from EGUs. Facility operators do, however, have to report the 

emissions of GHGs that are not included under Section 821, such as methane (CH4) 

and nitrous oxide (N2O).

• 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. The bottom-up approach to data collection in the GHGRP can help reduce 

uncertainty in emissions estimates for specific industries, and more broadly, helps

EPA transition to use of the 2006 IPCC Guidelines for National Greenhouse Gas 

Inventories, which will be required to meet international reporting obligations under 

the United Nations Framework Convention on Climate Change in the near future.

• EPA published the Federal Requirements Under the Underground Injection Control 

(UIC) Program for Carbon Dioxide Geologic Sequestration (GS) Wells Final Rule 

(henceforth referred to as the “GS Rule”) (75 FR 77230, December 10, 2010). EPA 

determined that the GHGRP is complementary to and builds on EPA’s UIC permit 

requirements. Requirements under the UIC program are focused on demonstrating 

that underground sources of drinking water are not endangered as a result of CO2

injection into the subsurface, while requirements under the GHGRP through subpart 

RR enable reporters to quantify the amount of CO2 that is geologically sequestered. 

For example, the UIC Class VI permit (including the Testing and Monitoring Plan) 

and subpart RR’s monitoring, reporting, and verification plan have separate 

monitoring objectives. 

• EPA reviewed the Internal Revenue Service (IRS) Notice 2009-83 Credit for Carbon 

Dioxide Sequestration under Section 45Q. To claim the credit, a taxpayer must follow 

general monitoring and verification principles, calculate CO2 sequestered in the fiscal 

year using a mass-balance equation, and report to IRS the amount of qualified CO2
ICR for the GHGRP Page 8 August 2015

sequestered in the fiscal year. However, the level of reporting and transparency of the 

IRS data collected would not meet the verification needs of the GHGRP. The IRS 

reporting requirement expires after 75 million metric tons of CO2 is reported as 

sequestered to IRS, data reporting is only as robust as to meet the standards in the 

case of an IRS audit, and the IRS does not outline procedures for quantifying and 

reporting any CO2 leakage that may occur as is necessary for the rule. Therefore, 

EPA has concluded that the IRS data would not meet the needs outlined in 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 (e.g., 

California, Massachusetts, North Carolina, and New Jersey). To reduce burden on 

reporters and program agencies, the Agency shares emissions data with the exception 

of any CBI with relevant agencies or approved entities using, where practical, shared 

tools, and infrastructure.

3(b) Public Notice Required Prior to Information Collection Request (ICR)

Submissions to OMB

This Supporting Statement is appended to an FR notice that is being published prior to 

submission of this GHGRP ICR to the Office of Management and Budget (OMB) in compliance 

with the Paperwork Reduction Act (44 USC 3501 et seq.). The public comment period for this 

notice is 60 days. A second FR notice will be published when the ICR is submitted to OMB for 

review, allowing another opportunity for public review and comments.

3(c) Consultations

To learn of ways to minimize burden on reporters, EPA engages in consultations with 

reporters on a regular basis. Since the GHGRP’s inception, EPA has conducted over 130 training 

webinars reaching over 16,000 people and has responded to approximately 33,000 questions 

received by our help desk. EPA also communicates with GHGRP reporters directly after every 

data submission deadline during our annual verification period. The programs generally 

maintains an open-door policy and has consulted on numerous occasions with trade associations 

as well as individual companies with issues or concerns. As a result of these consultations, EPA 

has identified specific sections of the rule language that were either not clear or did not have the 

intended effect. EPA has promulgated amendments to the rule to resolve these issues and to 

correct technical and editorial errors that have been identified. 

To monitor the usefulness of this data collection, the GHGRP staff are in regular 

communication with other EPA programs that use the data, such as voluntary and mandatory 

GHG reduction programs within the Office of Air. EPA also consults regularly with State, local, 

and tribal environmental control agencies, environmental groups, research entities, and other 

nongovernmental organizations.
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3(d) Effects of Less Frequent Collection

Annual reporting of the data is necessary to ensure that the Agency’s objectives for the 

GHGRP are met. Annual reporting is critical for assessing year to year variances in emissions 

both at the facility and sector level. With less frequent reporting, the EPA would be unable to 

discern whether changes in emissions are individual year variances or multi-year trends. As the 

Agency evaluates potential GHG emission reduction opportunities, it is critical to be able to 

analyze up-to-date, multi-year data for all sectors covered by the program. For example, GHGRP 

collects critical information necessary to evaluate potential GHG reduction approaches, such as 

number of facilities in a sector, production or capacity of each facility, abatement technologies 

used across a sector, number of facilities using continuous emission monitoring systems, and 

chemical-specific GHG emission information. These data are essential for understanding the 

sources that would be impacted by potential regulations, emissions monitoring approaches and 

abatement technologies currently employed within a sector, and the general emissions profile of 

the industry. Furthermore, an annual collection frequency supports the critical linkage described 

in section 2(b) between the GHGRP and the Inventory, an analysis that EPA is obligated to 

publish on an annual basis according to international agreement.

Annual GHG data also allow EPA to monitor and assess the combined result of multiple 

efforts to reduce GHG emissions. Specifically for the period covered by this ICR renewal (2016 

– 2018), annual reporting will allow the Agency to effectively track the success of both recent 

and upcoming climate change regulations as well as other efforts undertaken to reduce

emissions. In addition, certain data that are inputs to emission equations were collected by 

facilities between 2010 and 2014 but were deferred for reporting to EPA until March 31, 2015.

Some of these data, such as the inputs to emission equations for the Petroleum and Natural Gas 

Systems source category, were collected for the first time in 2015. These data include equipment 

counts, flare combustion efficiency, and volume of sales oil from all wells. Annual data from 

2016-2018 will allow EPA to analyze year-to-year trends in these data for the first time. Other 

data that were deferred from reporting until 2015 are now submitted to the Inputs Verifier Tool 

rather than reported to the EPA, as discussed in Section 1(b) of this document. The Inputs 

Verifier Tool, first used in 2015, has allowed the Agency to improve its verification of emissions 

by using entered inputs to calculate emissions and conducting verification checks on the inputs to 

the equations. Receiving annual data in 2016-2018 will allow EPA to analyze year-to-year trends

on multiple years of data collected under this improved verification approach.

With annual data, stakeholders can monitor changes in facility emissions over time with 

respect to comparable facilities in the industry. Annual reporting also lines up with the reporting 

frequency of all existing State GHG reporting programs as well as other Agency and State 

programs that require reporting of environmental data.

The frequency with which facilities and suppliers applicable to GHGRP monitor, sample, 

or measure data varies across the 41 subparts, from weekly to once per year. These collection 

frequencies are necessary to ensure adequate data quality and were designed to match the

variability of activities conducted by each source category.
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3(e) General Guidelines

Although the GHGRP generally has a three year requirement for record retention

consistent with the retention period specified in the general information collection guidelines in 5 

CFR 1320.5(f) of the OMB regulations implementing the Paperwork Reduction Act, facilities 

using the verification software within e-GGRT called IVT for any subpart are required to retain

all records for five years.

The EPA has determined that five years is a reasonable time period given the large 

number of reporters and the likely increase in follow-up activities due to IVT. It is important that

relevant records are available to the EPA for follow-up activities with facilities, including on-site 

audits if necessary, regarding potential errors, discrepancies, or questions. Should an EPA 

inspector visit a facility, it is important to be able to examine not only the current year’s records 

but those from previous years as well. Employing year-to-year comparisons are useful for 

verifying the current year’s data. A 5-year record retention period ensures the availability of 

relevant records for the follow-up activities described above. EPA proposed the change from 

three to five years for record retention for some facilities through a rulemaking process and took 

all comments received into consideration upon promulgating the final action.

This collection of information is consistent with all other OMB guidelines under 5 CFR 

1320.5.

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. EPA typically makes CBI determinations 

under the CAA on a case-by-case basis under 40 CFR 2.301. Due to the large numbers of entities 

reporting under the GHGRP and the large number of data reporting elements, EPA concluded 

that case-by-case determinations would not result in a timely release of emission data and other

non-CBI data (see proposed CBI rule, July 7, 2010, 75 FR 39094). Therefore, the EPA has 

published confidentiality determinations for most information reported under the GHGRP (May 

26, 2011, 76 FR 30782; August 13, 2012, 77 FR 48072; August 24, 2012, 77 FR 51477; 

November 13, 2013, 78 FR 68162; November 29, 2013 78 FR 71904; January 22, 2014, 79 FR 

3507; October 24, 2014, 79 FR 63750; and November 25, 2014, 79 FR 70352). These

confidentiality determinations 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.

3(g) Sensitive Questions

This information collection does not ask any questions concerning sexual behavior or

attitudes, religious beliefs, or other matters usually considered private.
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4. THE RESPONDENTS AND THE INFORMATION REQUESTED

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

that must report their GHG emissions to EPA to comply with the rulemaking. To facilitate the 

analysis, EPA has divided respondents into groups that align with the source categories identified 

in the rule.

This section lists the industry sectors (i.e., GHG source categories) that must report to the 

GHGRP, the data items required of program participants, and the activities in which participants 

must engage to collect, assess, and in some cases submit the required data items.

4(a) Respondents/North American Industrial Classification Systems (NAICS) Codes

Reporting facilities include, but are not limited to, those operating one or more units that 

exceed the CO2e threshold for the industry sectors listed below or those in the categories in 

which all must report, such as petroleum refining facilities and all other large emitters listed in 

Table A-3 of 40 CFR 98.2(a)(1). Additionally, the GHGRP also requires reporting of certain 

emissions information associated with mobile sources (e.g., for permit applications or emissions 

control certification testing procedures).

Industry sectors are listed below by their corresponding subpart of the rule and their 

NAICS code for reference.

Part and Subpart NAICS code(s)

Parts 86, 87, 89, 90, 94, 

1033, 1039, 1042, 1045, 

1048, 1051, 1054, 1064, 

1065

481 Air transportation; 482 Rail transportation; 483 Water 

transportation

Part 98

C. General Stationary 

Fuel Combustion 

Sources

Facilities operating boilers, process heaters, incinerators, turbines, 

and internal combustion engines: 211 Extractors of crude 

petroleum and natural gas; 321 Manufacturers of lumber and 

wood products; 322 Pulp and paper mills; 325 Chemical 

manufacturers; 324 Petroleum refineries, and manufacturers of 

coal products; 316, 326, 339 Manufacturers of rubber and 

miscellaneous plastic products; 331 Steel works, blast furnaces; 

332 Electroplating, plating, polishing, anodizing, and coloring; 

336 Manufacturers of motor vehicle parts and accessories; 221 

Electric, gas, and sanitary services; 622 Health services; 611 

Educational services

D. Electricity Generation 221112 Fossil-fuel fired electric generating units, including units 

owned by federal and municipal governments and units located in 

Indian Country

E. Adipic Acid 

Production

325199 Adipic acid manufacturing facilities

F. Aluminum Production 331312 Primary Aluminum production facilities
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Part and Subpart NAICS code(s)

G. Ammonia 

Manufacturing

325311 Anhydrous and aqueous ammonia manufacturing facilities

H. Cement Production 327310 Portland Cement manufacturing plants

I. Electronics 

Manufacturing

334111 Microcomputers manufacturing facilities; 334413 

Semiconductor, photovoltaic cells (PV) (solid-state) device 

manufacturing facilities; 334419 Liquid crystal display (LCD) 

unit screens manufacturing facilities; 334419 

Microelectricomechanical devices (MEMS) manufacturing 

facilities

K. Ferroalloy Production 331112 Ferroalloys manufacturing facilities

L. Fluorinated GHG 

Production

325120 Industrial gases manufacturing facilities

N. Glass Production 327211 Flat glass manufacturing facilities; 327213 Glass 

container manufacturing facilities; 327212 Other pressed and 

blown glass and glassware manufacturing facilities

O. HCFC-22 Production 

and HFC-23 Destruction

325120 Chlorodifluoromethane manufacturing facilities

P. Hydrogen Production 325120 Hydrogen manufacturing facilities

Q. Iron and Steel 

Production

331111 Integrated iron and steel mills, steel companies, sinter 

plants, blast furnaces, basic oxygen process furnace (BOPF) shops

R. Lead Production 331419 Primary lead smelting and refining facilities; 331492 

Secondary lead smelting and refining facilities

S. Lime Manufacturing 327410 Calcium oxide, calcium hydroxide, dolomitic hydrates 

manufacturing facilities

T. Magnesium 

Production 

331419 Primary refiners of nonferrous metals by electrolytic 

methods; 331492 Secondary magnesium processing plants

U. Miscellaneous Uses 

of Carbonate

Facilities included elsewhere

V. Nitric Acid 

Production

325311 Nitric acid manufacturing facilities

W. Petroleum and 

Natural Gas Systems

486210 Pipeline transportation of natural gas; 221210 Natural gas 

distribution facilities; 21111 Extractors of crude petroleum and 

natural gas; 211112 Natural gas liquid extraction facilities

X. Petrochemical 

Production

32511 Ethylene dichloride manufacturing facilities; 325199 

Acrylonitrile, ethylene oxide, methanol manufacturing facilities; 

325110 Ethylene manufacturing facilities; 325182 Carbon black 

manufacturing facilities

Y. Petroleum Refineries 324110 Petroleum refineries

Z. Phosphoric Acid 

Production

325312 Phosphoric acid manufacturing facilities

AA. Pulp and Paper 

Manufacturing

322110 Pulp mills; 322121 Paper mills; 322130 Paperboard mills

BB. Silicon Carbide 

Production

327910 Silicon carbide abrasives manufacturing facilities

CC. Soda Ash 

Manufacturing

325181 Alkalis and chlorine manufacturing facilities, 212391 

Soda ash, natural, mining and/or beneficiation

DD. Electrical 

Equipment Use

221121 Electric bulk power transmission and control facilities
ICR for the GHGRP Page 13 August 2015

Part and Subpart NAICS code(s)

EE. Titanium Dioxide 

Production

325188 Titanium dioxide manufacturing facilities

FF. Underground Coal 

Mines

212113 Underground anthracite coal mining operations; 212112 

Underground bituminous coal mining operations

GG. Zinc Production 331419 Primary zinc refining facilities; 331492 Zinc dust 

reclaiming facilities, recovering from scrap and/or alloying 

purchased metals

HH. Municipal Solid 

Waste Landfills

562212 Solid waste landfills; 221320 Sewage Treatment Facilities

II. Industrial Wastewater 

Treatment

322110 Pulp mills; 322121 Paper mills; 322122 Newsprint mills; 

322130 Paperboard mills; 311611 Meat processing facilities; 

311411 Frozen fruit, juice, and vegetable manufacturing facilities; 

311421 Fruit and vegetable canning facilities; 325193 Ethanol 

manufacturing facilities; 324110 Petroleum refineries

LL. Suppliers of Coalbased Liquid Fuels211111 Coal liquefaction at mine sites

MM. Suppliers of 

Petroleum Products

324110 Petroleum refineries

NN. Suppliers of Natural 

Gas and Natural Gas 

Liquids

221210 Natural gas distribution facilities; 211112 Natural gas 

liquid extraction facilities

OO. Suppliers of 

Industrial Greenhouse 

Gases

325120 Industrial greenhouse gas manufacturing facilities

PP. Suppliers of Carbon 

Dioxide

325120 Industrial greenhouse gas manufacturing facilities

QQ. Importers and 

Exporters of Pre-charged 

Equipment and ClosedCell Foams

423730 Air-conditioning equipment (except room units) merchant 

wholesalers; 333415 Air-conditioning equipment (except motor 

vehicle) manufacturing; 336391 Motor vehicle air-conditioning 

manufacturing; 423620 Air-conditioners, room, merchant 

wholesalers; 443111 Household Appliance Stores; 423730 

Automotive air-conditioners merchant wholesalers; 326150 

Polyurethane foam products manufacturing; 335313 Circuit 

breakers, power, manufacturing; 423610 Circuit breakers 

merchant wholesalers

RR. Geologic 

Sequestration of Carbon 

Dioxide

211 Oil and gas extraction projects using CO2 enhanced oil and 

gas recovery; 211111 or 211112 Projects that inject acid gas 

containing CO2 underground; N/A CO2 geologic sequestration 

projects

SS. Electrical Equipment 

Manufacture or 

Refurbishment

33531 Power transmission and distribution switchgear and 

specialty transformers manufacturing facilities

TT. Industrial Waste 

Landfills

562212 Solid waste landfills; 322110 Pulp mills; 322121 Paper 

mills; 322122 Newsprint mills; 322130 Paperboard mills; 311611 

Meat processing facilities; 311411 Frozen fruit, juice, and 

vegetable manufacturing facilities; 311421 Fruit and vegetable 

canning facilities; 221320 Sewage treatment facilities
ICR for the GHGRP Page 14 August 2015

Part and Subpart NAICS code(s)

UU. Injection of Carbon 

Dioxide

211 Oil and gas extraction projects using CO2 enhanced oil and 

gas recovery; 211111 or 211112 Projects that inject acid gas 

containing CO2 underground

Mobile Sources 333618 Heavy-duty, non-road, aircraft, locomotive, and marine 

diesel engine manufacturing; 336312 Small non-road, and marine 

spark-ignition engine manufacturing facilities; 336999 Personal 

watercraft manufacturing facilities; 336991 Motorcycle 

manufacturing facilities

4(b) Information Requested

(i) Data Items

Reporting and Recordkeeping Requirements

The GHGRP applies to certain facilities that emit GHGs and to suppliers of products that 

release GHGs if combusted, oxidized, or used. Applicability depends on the source categories 

located at the facility and, for some source categories, the emission level or production capacity. 

Fossil fuel and industrial GHG suppliers, motor vehicle and engine manufacturers, and facilities 

that emit 25,000 metric tons or more of CO2e/year report GHG data to EPA annually.

Specifically, the facilities in the source list of Table A-3 of 40 CFR 98.2(a)(1) are subject 

to an all-in threshold, in which they report emissions regardless of a CO2e/year emissions 

threshold. EPA established the all-in source categories for simplification because all or almost all 

of the sources in these subparts have emissions well over the 25,000 CO2e/year threshold. These 

emitters report all emissions from all-in emission source categories (Table A-3) as well as 

threshold source categories (Table A-4 of 40 CFR 98.2(a)(2) source list), stationary fuel 

combustion sources (subpart C), and miscellaneous use of carbonates (subpart U). Suppliers in 

the source list of Table A-5 of 40 CFR 98.2(a)(4) report all applicable products in Table A-5.

In addition, facilities that do not contain sources listed in Table A-3, but that emit at least 

25,000 metric tons CO2e/year in combined emissions from stationary combustion sources and 

other sources listed in Table A-4 report emissions from stationary fuel combustion sources 

(subpart C), miscellaneous use of carbonates (subpart U), and all applicable source categories

listed in Table A-4. Facilities with only combustion emissions that emit at least 25,000 metric 

tons CO2e/year are only required to report emissions from combustion sources.

Respondents comply with the following categories of requirements (if applicable): the

General Provisions applicable to all sources; stationary combustion; and requirements applicable 

to other specific source categories identified in subparts D through UU of the rule. In addition, 

vehicle and engine manufacturers subject to the requirements of CFR parts 86, 87, 89, 90, 94, 

1033, 1039, 1042, 1045, 1048, 1051, 1054, and 1065 report CO2, N2O, and CH4 emissions 

associated with the mobile sources that they produce.
ICR for the GHGRP Page 15 August 2015

Appendix B contains a list of the reporting requirements applicable to all facilities as well 

as those specific to each source category. Appendix C contains a similar list for recordkeeping 

requirements.

(ii) Respondent Activities

The owner or operator of a facility or supplier that is subject to the GHGRP’s reporting 

requirements reports total annual GHG emissions in metric tons of CO2e, as applicable. The 

primary tasks that reporting program respondents perform include:

1. Implement and update, as necessary, appropriate monitoring plans for each affected 

source and each affected unit at a source, as applicable;

2. Monitoring activities, where required;

3. Operation and maintenance activities associated with the monitoring, including 

quality assurance activities; 

4. Ensuring data quality, preparing annual reports for submission to EPA, and 

submitting these reports to EPA; 

5. Potentially responding to questions or error messages from EPA; and 

6. Maintaining records for a period of three years or five years, as specified in the 

GHGRP.

Respondents that use CEMS also conduct tests to certify the operations of monitors, 

submit the results of these tests, and record emissions data (this activity generally is performed 

electronically).

Reports present the annual mass GHG emissions from each source category separately.

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

are required, the methods used to estimate missing data, and the QA/QC requirements depend on 

the specific source category.
ICR for the GHGRP Page 16 August 2015

5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION 

METHODS, AND INFORMATION MANAGEMENT

5(a) Agency Activities

EPA activities include the monitoring and verification of emission reports, database and 

software maintenance, communication and outreach, and program evaluation.

5(b) Collection Methodology and Management

EPA has established a central repository of inventory data for all respondents, the webbased Electronic Greenhouse Gas Reporting Tool (e-GGRT). Respondents report data 

electronically, and EPA stores the data in the database. Facilities and suppliers subject to the 

GHGRP register online through the e-GGRT system.

All data are submitted to EPA electronically in e-GGRT except the one-time Electronic 

Signature Agreement (ESA) which is submitted on paper. The tool has an XML reporting 

schema that allows facilities to upload GHG data directly in lieu of using the web forms provided 

through e-GGRT. The XML reporting schema contains all data elements needed to comply with 

the GHGRP. The electronic reports submitted under the GHGRP are subject to the provisions of 

40 CFR Part 3, specifying EPA systems to which electronic submissions must be made and the 

requirements for valid electronic signatures. Additionally, e-GGRT is designed to collect and 

store CBI.

The system follows Agency standards for design, security, data element and reporting 

format conformance, and accessibility. EPA designed the database in an attempt to minimize 

respondents’ burden by integrating the new reporting requirements with existing data collection 

and data management systems, when feasible. 

All facilities or suppliers must have a Designated Representative (DR) in order to report. 

The DR may appoint an Alternative Designated Representative (ADR) and agents. The DR, 

ADR, and agent are all able to enter data and submit the electronic report. Before submitting a 

report, the DR (or ADR) must certify the annual report. An electronic signature device (e.g., a 

PIN or password) is required to submit a report.

EPA ensures data quality by conducting robust verification checks using both electronic 

software as well as manual review. EPA contacts facilities with reports that contain potential 

errors, and the statute requires that the facilities either resolve the error or explain that it is not an 

error in a timely manner. EPA makes all data accessible to the public on a web-based, userfriendly publication tool called FLIGHT.

5(c) Small Entity Flexibility

EPA took several steps to minimize the impacts on small entities. The Agency met 

several times with industry trade associations to discuss the reporting options considered and 
ICR for the GHGRP Page 17 August 2015

their possible impacts on small entities. EPA further minimized impacts on small entities by not 

requiring facilities below a certain emissions threshold to report their emissions.

Where feasible, EPA also uses existing GHG emissions estimation and reporting 

methodologies and provides simplified methodological options to reduce reporting burden.

According to the Agency’s analysis, a facility with stationary combustion units that have a 

maximum rated heat input capacity of less than 30 mmBtu/hr, operating full time with any type 

of fossil fuel, would not exceed 25,000 metric tons CO2e/year. Exempting facilities based on 

combustion unit capacity has allowed for small entities to perform a simple calculation to 

determine if they are even required to estimate emissions for applicability purposes.

Additionally, EPA minimized the impact on small entities in subpart NN (Suppliers of 

Natural Gas and Natural Gas Liquids) by amending the reporting threshold from an all-in 

threshold to a capacity-based threshold. EPA revised the applicability threshold so that only local 

distribution companies (LDCs) that deliver 460,000 thousand standard cubic feet (mscf) or more 

of natural gas per year are subject to the GHGRP (75 FR 79092; December 17, 2010).

The rule includes a mechanism in 40 CFR 98.2 to allow facilities and suppliers that report 

less than 25,000 metric tons of CO2e/year for five years or less than 15,000 metric tons 

CO2e/year for three years to cease annual reporting to EPA. 

5(d) Collection Schedule

For each reporting year, facilities collect data and calculate emissions at varying 

frequencies, as described in the GHGRP, and summarized in Appendices B and C. Facilities then

submit GHG reports on March 31 of each calendar year for GHG emissions that occurred in the 

previous calendar year. EPA conducts a verification process of the data from April 1 through the 

end of September of each calendar year then publishes the data in FLIGHT by October. During 

the verification period, EPA notifies certain facilities that their report may contain errors. The 

regulation requires that these facilities resubmit their reports with corrected data or respond to 

the notification with an explanation of why it is not an error within 45 days of receiving the 

notification. Facilities may request a 30-day extension if necessary, which is automatically 

granted by EPA.

Facilities or suppliers that cease annual reporting as described in Section 5(c) must first 

submit a notification to discontinue reporting to the Administrator no later than March 31 of the 

year immediately following the fifth (or third) consecutive year of emissions less than 25,000 (or 

15,000) tons CO2e/year. Likewise, facilities or suppliers that change operations such that all 

applicable GHG-emitting processes and operations cease to operate are exempt from reporting in 

the years following the year in which cessation of such operations occurs, provided that the 

owner or operator submits a notification to the Administrator no later than March 31 of the year 

immediately following the operation cessation.
ICR for the GHGRP Page 18 August 2015

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

This section presents 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). EPA estimates that, over the three years covered by 

this request, the total respondent burden associated with this reporting will average 878,911

hours per year and the cost of all respondents of the information collection will average 

$101,837,411 per year.

Section 6(a) of this ICR 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. EPA estimates that the total 

annual burden to all affected entities is 878,911 hours per year over the three years covered by 

this information collection. EPA also estimated the number of responses, or actions taken as a 

result of the rule, per respondent (facility) per year; for facilities collecting samples on a daily 

basis, this means a minimum of 365 responses per year. Exhibit 6.1 presents aggregate burden by 

sector only; for the details of burden calculations, please see the cost appendices.

6(b) Estimating Respondent Costs

Costs to respondents associated with this information collection include labor costs (i.e., 

the cost of labor by facility staff to meet the rule’s information collection requirements) and nonlabor costs (e.g., the cost of purchasing and installing monitoring equipment or contractor costs 

associated with providing the required information).

To calculate labor costs, EPA used an approach consistent with the ICRs associated with 

the GHGRP currently approved by OMB. For all subparts the labor rates are: $66.25 for 

technical workers, $79.36 for managers, $28.48 for clerical support, and $108.61 for legal 

support. In addition, sector-specific labor rates are used for certain subparts in the oil and gas 

industry: $129.83 for senior managers, $118.86 for middle managers, $99.18 for engineers, 

$52.84 for technicians, and $137.84 for geoscientists.

1 Non-labor costs (capital and O&M) for 

individual sectors are summarized in Exhibit 6-1.

EPA estimates that the total annual cost to all affected non-federal entities is $101.8

million over the three years covered by this information collection. Exhibit 6.1 presents

aggregate costs by sector. Appendix E contains the burden and costs for Subpart W, including 

the labor assumptions used for each activity required in Subpart W and the number of 

respondents expected in each industry segment. These costs and calculations are presented in 

 1 See Appendix D for details.
ICR for the GHGRP Page 19 August 2015

Appendix E-1, Appendix E-2, and Appendix E-3 for Year 1, Year 2, and Year 3 of the ICR 

Renewal period, respectively. The assumptions are documented in Appendix E-4. The burden 

and costs for each of the Subpart W industry segments are presented in Appendix E-5. Appendix 

F contains the burden and costs for Subpart RR.
ICR for the GHGRP Page 23 May 2015

Exhibit 6.1 Annual Average Respondent Burden and Cost

For the GHG Reporting Program

Source Category

Annual Average

Number of 

Respondents

Responses/

Respondent Total Responses Total Burden 

(hrs)

Total Labor Cost

($)

Capital Cost

($)

O&M Cost

($)

Total Cost

($)

C. Stationary Combustion a,f,l 2,139 40 85,148 218,943 14,502,958 785,398 2,265,658 17,554,014 

D. Electricity Generation a,f,k 1,243 9 11,187 67,305 4,458,009 0 0 4,458,009 

E. Adipic Acid Prod. a,d,l 3 28 84 561 36,832 176 28,321 65,328 

F. Aluminum Production a,l 11 17 182 3,303 230,624 0 2,635 233,259 

G. Ammonia Manufacturing a,d,l 23 107 2,462 2,273 149,958 1,347 154,959 306,265 

H. Cement Production a,d,l 96 510 48,986 27,719 1,853,021 615,135 1,893,118 4,361,274 

I. Electronics Manufacturing b,d,f,h,k 52 7 620 17,333 1,122,992 0 0 1,122,992 

K. Ferroalloy Production a,l 10 99 987 821 53,109 0 18,855 71,965 

L. Fluorinated Greenhouse Gas Prod a,i,k 16 7 113 2,983 178,806 43,846 18,501 241,153 

N. Glass Production a,l 109 102 11,122 8,747 575,947 0 126,573 702,520 

O. HCFC-22 Production and HFC-23 

Destruction a,l 4 92 368 614 36,629 0 0 36,629 

P. Hydrogen Production a,d,k 109 23 2,579 13,542 530,509 0 242,793 773,302 

Q. Iron and Steel Production a,d,k 126 92 11,597 36,745 2,095,712 0 326,367 2,422,079 

R. Lead Production a,d,l 14 102 1,429 1,663 107,770 0 25,110 132,880 

S. Lime Manufacturing a,d,l 75 544 40,803 16,450 1,087,256 519,409 1,365,521 2,972,185 

T. Magnesium Production a,k 9 9 81 1,686 111,025 0 1,580 112,605 

U. Misc. Uses of Carbonate a,e,l 15 102 1,531 1,204 79,259 0 17,418 96,677 

V. Nitric Acid Production a,d,l 35 42 1,473 6,385 429,369 15,577 192,611 637,557 

W. Oil and Natural Gas Systems a,j,k 2,203 125 275,375 188,063 18,657,145 1,124,604 8,377,990 28,159,739

X. Petrochemical Prod. a,d,l 65 92 5,983 13,287 844,251 0 690,914 1,535,165 

Y. Petroleum Refineries a,l 146 92 13,438 57,512 3,690,734 198,799 256,981 4,146,514 

Z. Phosphoric Acid Prod a,l 12 544 6,528 2,625 173,514 83,105 218,483 475,103 

AA. Pulp & Paper Mnfctrng a,d,l 110 92 10,125 11,276 735,006 0 0 735,006 

BB. Silicon Carbide Production a,l 1 37 37 153 10,137 0 230 10,367 

CC. Soda Ash Manufacturing a,l 5 93 465 1,164 77,734 0 10,405 88,139 

DD. Sulfur Hexafluoride (SF6) from Electric 

Power Systems a,k 121 7 852 9,127 549,694 0 0 549,694 

EE. Titanium Dioxide Production a,l 7 93 651 1,091 71,987 0 3,219 75,206 

FF. Underground Coal Mines a,f,k 117 21 2,428 40,599 2,590,282 259,887 538,069 3,388,238 

GG. Zinc Production a,f,l 5 108 540 547 35,714 969 4,599 41,283 

HH. Landfills a,f,k 1,187 92 109,253 45,007 2,860,636 75,428 145,564 3,081,628 

II. Wastewater a,k 155 7 1,091 3,818 243,868 389,226 1,394,551 2,027,645 

LL. Suppliers of Coal-based Liquid Fuels, 

MM. Suppliers of Petrol. Prod. b,f,k 265 99 26,127 11,252 837,532 0 0 837,532 

NN. Supplies of Nat Gas and Nat Gas Liquids b,f,k 503 53 26,784 32,997 2,101,867 0 0 2,101,867 

OO. Suppliers of Industrial GHG b,k 58 15 872 3,236 211,248 0 0 211,248 

PP. Suppliers of CO2 b,k 141 36 5,082 6,380 410,267 0 0 410,267 

QQ - Imports and Exports of Fluorinated GHGs 

in Products b,k 39 7 275 2,731 179,904 0 0 179,904 

RR. Geologic Sequestration of Carbon Dioxide c,k 5 Varies Varies 3,067 381,497 2,855,835 1,758,417 4,995,748
ICR for the GHGRP Page 24 May 2015

Exhibit 6.1 Annual Average Respondent Burden and Cost

For the GHG Reporting Program

(continued)

Source Category

Annual Average

No. 

Respondents

Responses/

Respondent

Total 

Responses

Total Burden 

(hrs)

Total Labor Cost

($)

Capital Cost

($)

O&M Cost

($)

Total Cost

($)

SS - SF6 Equipment Producers a,k 6 7 42 264 15,260 0 83 15,343 

TT -Industrial Landfills a,f,l 174 7 1,225 11,739 747,763 10,983 88,023 846,769 

UU. Injection of Carbon Dioxide b,k 95 0 1,138 3,928 250,628 0 246,408 497,036 

Mobile Sources 390 1 390 771 $43,796 $10,984,154 $99,327 11,127,277 

TOTALS 9,899 72 709,454 878,911 $63,360,249 $17,963,878 $20,513,283 $101,837,411

a

 Number of respondents based on RY2013 data as of 4/24/15. b

 Number of respondents based on RY2013 data as of 5/13/15. c

 Assumed that the one facility that submitted a plan in calendar year 2015 will be approved by EPA, will begin reporting in Year 1 of the ICR Renewal, and will continue reporting in Year 2 and Year 3. d Additional reporting elements were added as a result of the Inputs Rule (79 FR 63750, October 24, 2014). e Burden and costs were not calculated for Subpart U in past years. EPA based costs on Subpart N, due to similarities in testing and calculations required by the rules. f Some facilities subject to this subpart notified the EPA that GHGRP reporting was discontinued under 98.2(i), so were subtracted from the number of respondents determined according to footnote “a” or footnote “b”. h See 78 FR 68162 (November 13, 2013) for significant rule changes since the previous ICR Renewal.

i See 79 FR 73750 (December 11, 2014) for rule changes since the previous ICR Renewal. j See Appendix E for details.

k Three year requirement for record retention under GHGRP. l Five year requirement for record retention under GHGRP.
ICR for the GHGRP Page 25 May 2015

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 oversight 

of the reporting program and required reporting by federally owned GHG generating facilities.

EPA Burden and Cost for Program Oversight 

EPA activities associated with the GHG reporting program include 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. EPA 

estimates that it will devote up to 12 full time equivalents (FTEs), or an estimated 24,960 hours 

to these activities.

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

overhead and benefits for Agency staff to be $53.42. To derive this figure, EPA multiplied the 

hourly compensation at GS-12, Step 5 on the 2015 GS pay scale ($33.39) by the standard 

government benefits multiplication factor of 1.6 to account for overhead and benefits.2

In addition to the labor cost, EPA will incur a non-labor cost of approximately $10.7

million in each of the three years of the information collection for developing guidance, training, 

responding to stakeholders, communication and outreach, database maintenance, and other 

contractor support.

Exhibit 6.2 presents the annual Agency burden and cost.

 2 http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2015/GS_h.pdf
ICR for the GHGRP Page 26 May 2015

Exhibit 6.2 Annual Agency Burden and Cost

Information Collection 

Activity

Annual 

Responses

Total Annual 

Burden

Labor Cost Non-Labor 

Cost

Total Annual 

Cost

Developing Guidance, 

Conducting Training, Audits, 

and General Oversight

1 24,960 $1,333,363 $10,666,667 $12,000,030

6(d) Estimating the Respondent Universe and Total Burden and Costs

The number of respondents in each sector that perform the required activities under this 

information collection is presented in Exhibit 6.1. The required activities depend on whether the 

facility must report its GHG emissions and on the applicable sector-specific reporting 

requirements. These activities are described in Section 4(b) of this ICR.

6(e) Bottom Line Burden Hours and Costs

The bottom line burden hours and costs are shown in Exhibit 6.3.
ICR for the GHGRP Page 27 May 2015

Exhibit 6.3 Bottom Line Annual Burden and Cost

Number of Respondents 9,899 From Exhibit 6.1

Total Annual Responses 709,454 From Exhibit 6.1

Number of Responses per 

Respondent

72 = 709,454 Total annual responses from above /

9,899 Total respondents from above

Total Respondent Hours 878,911 From Exhibit 6.1

Hours per Response

1.24 = 878,911 Total annual hours from above /

709,454 Total responses from above

Total Labor Costs 63,360,249 From Exhibit 6.1

Annual O&M and Capital Cost 38,477,161 From Exhibit 6.1

Total Respondent Cost 

(labor + non) 101,873,411 From Exhibit 6.1

Total Hours 

(Respondents and Agency)

903,871 878,911 Total respondent hours from above +

24,960 Total EPA hours from Exhibit 6.2

Total Cost 

(Respondents and Agency)

$113,837,441 $101,837,411 Total respondent cost from above +

$12,000,030 Total EPA cost from Exhibit 6.2

6(f) Reasons for Change in Burden

This section presents the change in burden and explains the reasons for the change in 

burden. Exhibit 6.4 summarizes the adjustments that have affected the overall burden inventory 

for the final GHGRP ICRs. There is a decrease of 102,121 hours and an increase of $11.0 million

in the total estimated respondent burden compared with that identified in the GHGRP ICR 

renewed by OMB in 2013. This change reflects a number of updates in this ICR renewal as 

compared to the previous ICR renewal. Overall, EPA adjusted the labor rates and capital costs to 

reflect 2013 dollars and decreased the number of respondents to match the actual number of 

respondents for each subpart in reporting year 2013 (RY2013). Several subpart specific updates

were also made. First, EPA accounted for new segments and reporters added to Subpart W (FR 

publication forthcoming) to improve the Agency’s coverage of emissions from oil and natural 

gas systems. EPA also reevaluated the respondent costs related to all segments of subpart W (see 

Appendix E of this Supporting Statement) to more carefully and accurately reflect the activities 

conducted by respondents. Second, for subpart AA, capital costs and operation and maintenance 

costs were reduced to $0 because the costs were originally determined assuming the use of CO2

CEMS. The industry does not employ the use of CEMS and the industry is unlikely to begin 

using CEMS in the foreseeable future. Third, EPA decreased costs of subpart I as the result of 

amendments to the calculation and monitoring methodologies (78 FR 68162, 11/13/2013). 

Fourth, EPA increased costs of subpart RR to reflect the latest industry cost analyses and to 

assume an increase in projects (see Appendix F of this Supporting Statement). These changes are

the result of a program adjustment.
ICR for the GHGRP Page 28 May 2015

Exhibit 6.4 Summary of Changes in Annual Burden 

Title Current 

OMB 

Control 

Number

Agency 

Tracking 

Number

Number of 

Respondents

Total 

Burden 

(hrs)

Total Labor 

Cost ($)

Capital Cost 

($)

O&M Cost 

($)

Total Cost ($)

Information Collection Request for the Greenhouse Gas Reporting Program

Current 

Inventory

2060-0629 2300.10 11,039 981,032 62,655,000 17,252,763 10,940,000 90,848,000

Revised 

Inventory

2060-0629 2300.17 9,899 878,911 63,360,249 17,963,878 20,513,283 101,837,411

Change -1,140 -102,121 705,249 711,115 9,573,283 10,989,411

Reason for Change in Burden

• Adjusted the number of respondents

• Adjusted labor rates

• Adjusted capital costs and O&M costs for subpart AA

• Changed LOE assumptions for subpart W (see Appendix E of this Supporting Statement)

• Changed LOE assumptions for subpart RR

6(g) Burden Statement

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

878,911 hours per year for a three-year period. The average annual burden to EPA for this period

is estimated to be 24,960 hours for oversight activities. The annual public reporting and 

recordkeeping burden for this collection of information is estimated to average 1.24 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 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 

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

Docket ID Number EPA-HQ-OAR-2012-0333, 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), EPA West Building, 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) 
ICR for the GHGRP Page 29 May 2015

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-2012-0333 and 

OMB Control Number 2060-0629 on any correspondence.