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February 22, 2016
GHG reports: Deadlines and what's down the road
By Timothy P Fagan, Senior Legal Editor - EHS

Reporting season is in full swing. You may be wrapping up your Tier II chemical inventory reports, as the deadline is just days away, but for sources emitting greenhouse gases (GHG), there is no time to catch your breath. GHG emissions reports required by 40 CFR 98 are due on March 31. 

The U.S. Environmental Protection Agency’s (EPA) mandatory GHG reporting program applies to selected source categories of facilities that directly emit GHGs, the most common of which are stationary combustion units, and certain GHG suppliers.

Each source category has specific regulatory requirements outlining reporting thresholds, GHGs to be reported, calculation methods, and required recordkeeping. All GHG emissions estimates must be calculated in terms of carbon dioxide equivalents (CO2e) and submitted to the EPA using the agency’s electronic Greenhouse Gas Reporting Tool (e-GGRT).

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It’s all about the documentation

As with most environmental programs, claims of compliance are only valid if you have the records to prove it. The regulations under 40 CFR 98 clearly specify all the records that must be maintained by reporting facilities. For most sources, records must be maintained for a period of 3 years. However, facilities using the inputs verification tool must maintain records, including the input data saved locally to the facility’s computer, for a period of 5 years.

Check with your state

Before you consider yourself done with GHG reporting, be sure to check your state requirements to determine if there are separate, state-only GHG reporting requirements for your facility, or if GHG emissions must be included in the annual emissions inventory report submitted to the state regulatory agency.

What is down the road?

The GHG reporting program is a relatively new program, and as result, the EPA is still taking actions to optimize the program so that quality data is reported and is reflective of actual industry emissions while attempting to minimize the burden placed on the reporting sources. To that end, the EPA recently proposed amendments that will affect 30 source categories and will be phased in over the 2016, 2017, and 2018 reporting years. The proposed amendments include:

  • Changes to simplify and reduce the reporting burden for some sources by focusing on relevant data and removing unnecessary data or reporting requirements for activities producing few or no emissions. For example, for certain subparts, the pilot gas used to maintain a pilot flame at a flare tip will be excluded from the quantity of gas used to perform GHG emissions calculations because the quantity of pilot gas is relatively small compared to the total GHG emissions.
  • Changes to improve the quality of the data being reported. After a few years of reporting, the EPA has identified certain definitions, calculation methodologies, and monitoring methods that, if amended, will produce more accurate data.
  • Changes to calculation, monitoring, or measurement methods that may give reporters some flexibility and that may more accurately reflect industry processes and emissions.

The EPA is also proposing confidentiality determinations for new or substantially revised data elements. Typically, the EPA makes confidentiality determinations on a case-by-case basis, but due to the number of sources and data elements in the GHG reporting program, the EPA, through its regulations, determines which categories of data elements will be protected as confidential business information.

The take-away: Review the regulations

GHG reports are due March 31 of each year, and the calculation of GHG emissions must be done according to the requirements of the subpart that applies to your facility. However, as you become accustomed to submitting GHG reports as well as the monitoring that the applicable subpart may require, do not assume that monitoring or reporting may be done as it had been done in years past. The EPA is still optimizing the GHG reporting program and is frequently amending the regulations, so be sure you are aware of the changes and that you comply with the current requirements.

Download Anna Aumann's presentation, Air Emissions Reporting for 2016: Comprehensive Strategies for Managing Your Emission-Based Data, on-demand.

Anna Aumann serves as a managing consultant in Trinity’s Chicago office, managing projects in a variety of industries. She is involved in state, Title V, and Prevention of Significant Deterioration (PSD) permitting projects, New Source Performance Standard (NSPS) and National Emission Standard for Hazardous Air Pollutant (NESHAP) compliance assistance, air emissions reporting, toxic release inventories (TRI) and has developed and maintained client specific emission and compliance tools. Additionally, Ms. Aumann has provided on-site support. Ms. Aumann earned a M.S. degree and a B.S. degree in Mechanical Engineering from Purdue University. Her graduate work involved finite element modeling of thermal fracture in bimaterial thermal barrier coatings.

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