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August 23, 2013
GHG reporting amendments issued for electronics

In its latest action under the greenhouse gas (GHG) reporting program, the EPA has issued final amendments applicable to electronics manufacturing.  The changes include revisions to methods used to calculate GHG emissions, addition of a new emissions calculation method, and determinations on which reported elements are confidential business information (CBI) and which are not.

Authorized by Congress in 2008, the GHG reporting program requires that both large direct sources of GHGs, as well as suppliers of products that that would result in GHG emissions if released, combusted, or oxidized annually, report their GHG emissions data and other relevant information. The EPA issued its first implementing rule in 2009 and has followed that action with many amendments that address CBI and how specific industrial sectors should calculate their emissions.  In January 2012, the EPA made the first year of reported GHG data available to the public.   

Affected facilities

The current set of amendments affects facilities that manufacture electronics, including those that manufacture semiconductors (including light-emitting diodes), micro-electro-mechanical systems (MEMS), liquid crystal displays (LCDs), and/or photovoltaic (PV) cells.  According to the EPA, the amendments respond to concerns raised by the Semiconductor Industry Association.

Among the specific amendments are updates to default emissions factors for etching and nitrous oxide emitting processes; updates to default abatement system destruction or removal efficiency (DRE) factors; a stack testing alternative; and a revision to the DRE calculation methods applicable to fabs (a “fab” is the portion of an electronics manufacturing facility located in a separate physical structure that began manufacturing on a certain date).

Confidentiality 

The amendments provide CBI determinations for 10 data categories.  In general, the Clean Air Act does not allow the EPA to exclude “emissions data” from public disclosure. 

  • The amendments identified four data categories as emissions data that must be released to the public:
    1. Facility and unit identifier information (e.g., facility name and physical address);
    2. Emissions;
    3. Calculation methodology and methodological tier, and
    4. Data elements reported for periods of missing data that are not inputs to emissions equations.
  • Test and calibration methods are identified as neither emissions data nor CBI and would be released to the public.
  • CBI protections apply to:
    • Production/throughput data (that are not inputs to emissions equations);
    • Raw materials data (that are not inputs to emissions equations); and
    • Detailed process-specific and vendor information submitted in petitions to extend the use of best available monitoring methods (BAMM).
    • CBI determinations will be made by EPA on a case-by-case basis for two data elements:
      • Unit static characteristics (that are not inputs to emissions equations); and
      • Unit operating characteristics (that are not inputs to emissions equations).

      Compliance starts in 2015

      The amendments take effect for emissions occurring during the 2014 calendar year and reportable in early 2015; the amendments do not apply to reports that must be submitted to the EPA in March 2014.

      Click here for the final amendments to the GHG reporting requirements for electronics manufacturing.

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