### SUPPORTING STATEMENT PART A: INFORMATION COLLECTION REQUEST

FOR THE

GREENHOUSE GAS REPORTING PROGRAM

EPA ICR No. 23 0 0.1 7

October 201 5TABLE 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) Effec ts of Less Frequent Collection

................................ ................................ ............... 9 3(e) General Guidelines

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

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

................................ ................................ ................................ ...... 10

4. T HE 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 Mana gement

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

................................ ................................ ................................ 16 5(d) Collection Schedule

................................ ................................ ................................ ...... 17

6. E STIMATING 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

................................ ................................ ................................ ......... 28LIST 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 Na tural 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 A pplicable to Appendi ces E

- 1 , E

- 2, and E

- 3

E

- 5 Summary of Burden and Cost s for Petroleum and Natural Gas Syst ems (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 201 5 SUPPORTING STATEMENT

FOR THE GREENHOUSE GAS REPORTING PROGRAM

EPA ICR # 2300.1 7

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection

TITLE: “ Information Collection Request for the Greenhouse Gas Reporting Program (GHG RP ).”

ICR Number: 2300.1 7

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 G HGRP ) (74 FR 56260; October 30, 2009). The Rule, which became effective on December 29, 2009, requires reporting of greenhouse gas es ( GHGs ) from certain large facilities and suppliers

. I t does not require control of greenhouse gases. Instead, it requires t hat sources emitting or supplying above certain threshold levels of carbon dioxide ( CO 2 ) equivalent ( CO 2 e) 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 emission s are not reported to EPA because of disclosure concerns. Reporters instead enter t hose data into a web

based verification tool (Inputs Verifier Tool (IVT)) housed within e

- GGRT. IVT does not retain the entered inputs; instead it cal culate s emissions using entered “inputs to equations” and

conduct s verification checks at the time of data entry. IVT generate s 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 expire d on November 10, 2012. A

renewal wa s approved for three years and will expire on May 3 1 , 201 6

. Since the renewal w as approved

, seven amendments to the GHGR P have been finalized and have included incrementalICR for the GHGRP Page 2 August 201 5 updates to the ICR. The purpose for this ICR is to renew and revise the GHG Reporting Ru l e ICR

. Appendix A summarizes the ICRs associated with the GHGRP

.

There is a decrease of 1 02

, 121 hours and an increase of $ 1 1

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

in burden reflects a n adjustment in the number of respondents from projected to actu al, an adjustment of labor rates and capital costs to reflect 2013 dollars

, a re

- evaluation of the activities and costs associated with Subpart s W and RR , and the addition of new segments and new reporters under Subpart W

.ICR for the GHGRP Page 3 August 201 5 2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

Signed into law o n December 26, 2007, the FY200 8 Consolidated Appropriations A ct (henceforth referred to as the “Appropriations Act”) directed EPA to “ develop and publish a

draft rule not later than 9 mon ths 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

Uni ted 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 resulti ng 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 subm itted 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 th e 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 othe r things, provide such information the Administrator may reasonably require.

2(b) Practical Utility/Users of the Data

The GHG RP 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, allICR for the GHGRP Page 4 August 201 5 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 recen t 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 se ven 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 completi ons 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 stan dards 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 CO 2 is safely and securely

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

pro posed New So urce 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 va rying 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 cap acity, 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 gener ate 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 o n 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 release d 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 support ing the proposed Natural Gas STAR Methane Challenge Program

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

Methane C hallenge 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 forICR for the GHGRP Page 5 August 201 5 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 l everage 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 relativ e standing within their industry, and achieve and disseminate their environmental achievements. B usinesses and

other innovators can use the data to determin e 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, t ransparent, public data on emissions allows for accountability of polluters to the public stakeholder s who bear the cost of the pollution. This powerful data resource provide s 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 da ta 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 p ossible 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

simil ar 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.ICR for the GHGRP Page 6 August 201 5 3. NONDUPLICATION, CONSULTATIONS, A ND OTHER CO LLECTION

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 incl uding:

• Federal programs within the United States , such as t he 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 r egional GHG reporting programs , such a s 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 organizati ons, such as the World Resources Institute/World Business Council for Sustainable Development; and

• Programs from industrial trade organizations, such a s the Interstate Natural Gas

Association of America ’s GHG Emission Estimation Guidelines , the American Petroleum Institute’s Compendium of G HG Estimation Methodologies for the Oil and Gas Industry, and the World Business Council for Sustainable Development ’s Cement Sustainability Initiative’s CO 2 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 F ederal G overnment acted but also assist ed in quantifying the GHG reductions achieved by various policies

. Many of these programs collect different or addition al 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 supplement s and complement s , rather than duplicate s , existing programs’ data. Further, EPA has made significant efforts over the past several years to fac ilitate 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

Solution s 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.

D ocument ation of EPA’s review of GHG monitoring protocols used by federal and state voluntary and mandato ry GHG programs a s 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 theICR for the GHGRP Page 7 August 201 5 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

- 005 2 )

, and the January 27, 200 9 memorandum entitled Review of Existing State Greenhouse Gas Reporting Rules (which can be found in the do cket at

EPA

- HQ

- OAR

- 2008

- 05 08

- 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 help s EPA learn more about emissions from facilities not included in current

programs.

• EPA considered CO 2 data currently collected under Section 821 of the 1990 CAA

A mendments. To avoid duplication and because the Acid Rain program already requires reporting of high quality CO 2 data from electrical generating units (EGUs),

the GHGRP allows for use of the same CO 2 data rather than requiring additional reporting of CO 2 from EGUs. Facility o perators do, however, have to report the

emissions of GHGs that are not included under Section 821, such as methane ( CH 4 )

and n itrous oxide ( N 2 O )

.

• 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 app roach to data collection in the GHGRP can help reduce uncertainty in emissions estimates for specific industries, and more broadly, help s EPA transition to use of the 2006 IPCC Guidelines for National Greenhouse Gas Inventories, which will be required to m eet 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 Sequestrat ion (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 demonstra ting that underground sources of drinking water are not endangered as a result of CO 2 injection into the subsurface, while requirements under the GHGRP through subpart RR enable reporters to quantify the amount of CO 2 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 t he Internal Revenue Service (IRS) Notice 2009

- 83 Credit for Carb on Dioxide Sequestration under Section 45Q. To claim the credit, a taxpayer must follow general monitoring and verification principles, calculate CO 2 sequestered in the fiscal year using a mass

- balance equation, and report to IRS the amount of qualified CO 2ICR for the GHGRP Page 8 August 201 5 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 . T h e IRS reporting requirement expire s after 75 million metric tons of CO 2 is reported as

seques tered 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 CO 2 leakage that may occur as is necessary for th e rule. Therefore,

EPA has concl uded that the IRS data would not meet the needs outlined in the

GHGRP

.

• A number of programs at the state, t rib al, t erritorial , and l ocal 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 shar e s emission s data with the exception of any CBI with relevant agencies or approved entities using, where practical, shared

tools

, and infra structure.

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

Submissions to OMB

This Supporting Statement is appended to a n 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 6 0 days. A second FR notice will be published when the ICR is submitted to OMB for review, allowing another opportunity for publ ic 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 communicate s with GHGRP reporters directly after every data submission deadline during our annual verification period . The programs generally maintains an open

- d oor 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 regula r 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 triba l environmental control agencies, environmental groups, rese arch entities, and other nongovernmental organizations.ICR for the GHGRP Page 9 August 201 5 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 ye ar 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 emissio n 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 facili ties 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. Furth ermore, 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

a nd upcoming climate change regulations as well as other efforts undertaken to reduc e emissions. In addition, certain data that are in puts to emission equations were collected by

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

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

S ystems source category

, w ere collected for the first time in 2015. Th ese 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 w ere deferred from reporting until 2015 are now submitted to the Inputs Verifier Tool rather than reported to th e EPA, as discussed in Section 1(b) of this document

. The Inputs Verifier Tool, first used in 2015, has allow ed the A gency to improve its verification of emissions by using entered inputs to calculate emissions and conducting verification checks on the inputs to the equations. Receiving a nnual data in 2016

- 2018 wi ll allow EPA to analyze year

- to

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

W ith 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 f acilities and suppliers applicable to GHGRP monitor, sample,

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

f requencies are necessary to ensure adequate data quality and were designed to match the variability of activities conducted by each source category.ICR for the GHGRP Page 10 August 201 5 3(e) General Guidelines

A lthough 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 th e 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 gi ven the large number of reporters and the likely increase in follow

- up activities due to IVT . It is important that

relevant r ecords 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 on ly 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 ensure s the availability of

relevant records for the follow

- up activi ties 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 C AA and EPA regula tions

. 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

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

that case

- by

- case determin ations 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, 2 011, 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 reg ulations in 40 CFR Chapter 1, P art 2, S ubpart 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.ICR for the GHGRP Page 11 August 201 5 4. THE RESPONDEN TS AND THE INFORMATION REQUESTED

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

that must report their GHG emiss ions 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

R eporting facilities includ e , but are not limited to, t hose opera ting one or more units that

exceed the CO 2 e threshold for the industry sectors listed below or those in the categories in which all must report, such as petroleum refining facilitie s and all other l arge emitters listed in

Table A

- 3 of 40 CFR 98. 2(a)(1)

. Additionally, the GHGRP also require s 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 t ransportation; 482 Rail t ransportation; 483 Water

t ransportation

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 facilitiesICR for the GHGRP Page 12 August 201 5 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 faci lities ; 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 faciliti es; 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 an d 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; 211 11 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 facilitiesICR for the GHGRP Page 13 August 201 5 Part and Subpart NAICS code(s)

EE. Titanium Dioxide

Production 325188 Titanium dioxide manufacturing facilities

FF. Undergroun d Coal

Mines 212113 Underground an thracite 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 alloy ing 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 Coal

based Liquid Fuels 21 1111 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. Sup pliers 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 Closed

Cell 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

- co nditioners merchant wholesalers; 326150 Polyurethane foam products manufacturing ; 335313 Circuit breakers, power, manufacturing ; 423610 Circuit breakers

merchant wholesalers

RR. Geolo gic Sequestration of Carbon

Dioxide 211 Oil and gas extraction projects using CO 2 enhanced oil and gas recovery; 211111 or 211112 Projects that inject acid gas containing CO 2 underground; N/A CO 2 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 facilitiesICR for the GHGRP Page 14 August 201 5 Part and Subpart NAICS code(s) UU. Injection of Car bon

Dioxide 211 Oil and gas extraction projects using CO 2 enhanced oil and gas recovery; 211111 or 211112 Projects that inject acid gas containing CO 2 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

Re porting 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 sour ce 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 CO 2 e / year report GHG data to EPA annually.

Specifically, t he 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 CO 2 e/year emissions

threshold. EPA established the all

- in source categories for simplification because all o r almost all of the sources in these subparts have emissions well over the 25,000 CO 2 e/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 carbona tes (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

.

I n addition, facilities that do not contain sources listed in Table A

- 3, but that emit at least 25,000 metric tons CO 2 e /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 so urce categories

listed in Table A

- 4

. Facilities with only combustion emissions that emit at least 25,000 metric

tons CO 2 e /year are only required to report emissions from combustion sour ces.

Respondents comply with the following categories of requirements (if applicable): th e G eneral 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 part s 86, 87, 89, 90, 94, 1033, 1039, 1042, 1045, 1048, 1051, 1054, and 1065 re port CO 2 , N 2 O, and CH 4 emissions associated with the mobile sources that they produce.ICR for the GHGRP Page 15 August 201 5 Appendix B contains a list of the reporting r equirements applicable to all facilities as well as those specific to each source category. Appendix C contains a similar l ist for recordkeeping requirements.

(ii) Respondent Activities

The owner or operator of a facility or supplier that is subject to th e GHGRP ’s reporting requirements report s total annual GHG emissions in metric tons of CO 2 e , as applicable

. The primary tasks that reporting program respondents perform include :

1. I mplement and update, as necessary, appropriate monitoring plan s for each affected

source and each affected unit at a source , as applicable ; 2. Monitoring activities, where required;

3. Oper ation 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 r esponding 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 201 5 5. THE INFORMATION COLLECTED

– AGENCY ACTIVITIES, COLLECTION

METHOD S , 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 est ablish ed a central repository of inventory data for all respondents , the web

based Electronic Greenhouse Gas Reporting Tool (e

- GGRT). Respondents report da ta electronically, and EPA store s the data in the database. Facilities and suppliers subject to the GHGRP register online through th e 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 allow s facilities to up load GHG data directly in lieu of using the web fo rms 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 Par t 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 follow s 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

an d 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 D R

, 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, user

friendly 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 ind ustry trade associations to discuss the reporting options considered andICR for the GHGRP Page 17 August 201 5 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 use s existing GHG emission s estimation and reporting methodologies and provide s 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 CO 2 e/y ea r. Exempti ng 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 minimize d the impact on small entitie s 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 del iver 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 CO 2 e /year for five years or less than 15,000 metric tons

CO 2 e/year for three years to cease annual reporting to EPA

.

5(d) Collection Schedule

F or each reporting year, f acilities collect data and calculate emissions at varying frequencies, as described in the GHGRP , and summarized in Appendi ces B and C

. F acilities 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 v erification 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.

F acilities 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 CO 2 e/ year. Likewise, f acilities 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 Admini strator no later than March 31 of the year immediately following the operation cessation.ICR for the GHGRP Page 18 August 201 5 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 d escribed 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 87 8,911 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 r espondent 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 a nd cost. Section 6(f) provides r easons for any change in burden

. The burden statement for this information collection is in Section 6( g ).

6(a) Estimating Respondent Burden

Respondent burden estima tes are presented in Exhibit 6 .1

. EPA estimates that the total

annual burden to all affected entities is 87 8,911 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 mean s 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) Es timating 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 non

labor costs (e.g., the cost of purcha sing and installing monitoring equipment or contractor costs associated with providing the required information).

To calculate labor costs, EPA us ed an approach consistent with the ICRs associated with the GHGRP currently approved by OMB

. For all subparts the labor rates are: $ 6 6.25 for technical workers, $7 9. 36 for managers, $ 28.48 for clerical support, and $1 08.61 for legal

support. In addition, sector

- specific labor rates are used for certain subparts in the oil and gas industry : $ 1 29.83 for se n ior managers, $1 18.86 for middle managers, $ 9 9.18 for engineers, $ 52.84 for technicians , and $1 37.84 for geoscientists

. 1 Non

- labor costs (capital and O&M) for

individual sec tors are summarized in Exhibit 6

- 1.

EPA estimates that the total annual cost to all affected non

- federal entities is $ 1 0 1.8 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. The se costs and calculations are presented in

1 See Appendix D for details.ICR for the GHGRP Page 19 August 201 5 Appendix E

- 1 , Appendix E

- 2, and Appendix E

- 3 for Year 1, Year 2, and Year 3 of the ICR Renewal period , re spectively. 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 201 5 

### Exhibit 6.1 Annual Average Respondent Burden and Cost

F or 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 18 8

, 063 18,657,145 1, 124

, 604 8

, 377

, 99 0 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 CO 2 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, 995,748ICR for the GHGRP Page 24 May 201 5 

### 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 72 709,45 4 878,911 $6 3

, 360

, 249 $1 7

, 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 Subp art U in past years. EPA b ased 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 wa s 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 (D ecember 11, 2014) for rule changes since the previous ICR Renewal

. j See Appendix E for details.

k Th ree year requirement for record retention under GHGRP

. l Fi ve year requirement for record retention under GHGRP

.ICR for the GHGRP Page 25 May 201 5 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 pro gram and required reporting by federal l y owned GHG generating facilities.

EPA Burden and C ost for Program Oversight

EPA activities associated with the GHG rep orting 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 estimate d the average hourly labor rate for salary and overhead and benefits for Agency staff to be $ 5 3.42

. To derive this figure, EPA multiplied the hourly compensation at GS

- 12, Step 5 on the 201 5 GS pay scale ($ 3 3.39 ) by the standard government benefits multiplication factor of 1.6 to acco unt for overhead and benefits. 2

In addition to the labor cost, EPA wil l 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.pdfICR for the GHGRP Page 26 May 201 5 

### 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 $1 2, 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 act ivities 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 201 5 

### 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 87 8,911 From Exhibit 6.1

Hours per Response 1. 2 4 = 87 8

, 911 Total annual hours from above /

709,454 Total responses from above

Total Labor Costs 6 3,360,249 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) 9 03,871 87 8

, 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 +

$ 1 2,000,030 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 ICR s

. There is a de crease of 102

, 121 hours and an increase of $ 1 1.0 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 c osts to
reflect 2013 dollars and de crease d the number of respondents to match the actual number of responde nts for each subpart in reporting year 2013 (RY2013)

. S everal 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 oi l and natural gas systems. EPA also reevaluat ed 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, f or subpart AA, capital costs and operation and maintenance costs were reduced to $0 because the costs were originally determined assuming the use of CO 2 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 an d to assume an increase in projects (see Appendix F of this Supporting Statement)

. Th ese change s are the result of a program adjustment.ICR for the GHGRP Page 28 May 201 5 

### 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 17,25 2

, 763 10,940,000 90,848,000

Revised Inventory 2060

- 0629 2300.17 9,899 87 8

, 911 6 3

, 360

, 249 17, 963

, 878 20

, 513

, 283 101

, 837

, 411

Change

- 1,140

- 10 2

, 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

re sponse.

Burden means the total time, effort, or financial r esources 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 resp ond 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 201 5 566

- 1742. An electronic version of the public docket is available at h ttp:// 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, sel ect “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

.