Next up: GHG reports
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March 02, 2015
Next up: GHG reports
By Timothy P Fagan, Senior Legal Editor - EHS

Reporting season is in full swing.  The Tier II chemical inventory reporting deadline has come and gone, but for sources emitting greenhouse gases (GHGs) there is no time to catch your breath.  GHG emissions reports required by 40 CFR 98 are due on March 31. 

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EPA’s 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).

The deadline for submitting GHG emissions reports for the 2014 calendar year is fast approaching, and there are several changes impacting this year’s submittals, including:

  • Changes to listed GHGs and corresponding global warming potentials (GWPs);
  • Reporting of deferred data; and
  • Implementation of the Inputs Verifier Tool (IVT).

These changes are not universally applicable to all GHG reporting sources, but each potentially applies to a subset of source categories.

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Changes to GHGs and GWPs

The EPA has made changes to the GHGs and GWPs listed in Table A-1 of 40 CFR 98, Subpart A.  The additions included GWPs for specific fluorinated GHGs, fluorinated heat transfer liquids, and default GWP values for substances that do not have chemical-specific GWPs.  E-GGRT has been updated and will apply the correct GWPs to those source categories impacted by the changes.

Deferred data—its time has come

Under the Clean Air Act, all emissions data must be made available to the public and cannot be treated as confidential. However, certain inputs into the GHG emissions calculation equations under various subparts of 40 CFR 98 can be considered a trade secret or sensitive business information. Therefore, the reporting of certain data elements specified in Table A-7 of 40 CFR 98 for calendar years 2010 through 2013 was deferred.  But March 31, 2015, is the day by which it all must be reported.

E-GGRT has been updated to accommodate the deferred data for the affected source categories.  For the 2014 reporting year and going forward, collection of the deferred data is done through the normal E-GGRT data entry screens.  However, data for 2010 through 2013 will be entered onto special E-GGRT data entry screens specifically for such data and submitted with the 2014 report.

The IVT

The EPA launched the IVT within E-GGRT to verify data and ensure that affected source categories comply with GHG reporting requirements without having to report data elements for which there are disclosure concerns. Data elements identified in each applicable subpart will be required to be entered into the IVT. The data will not be retained by the IVT, but the IVT will calculate emissions using the inputs and conduct verification checks at the time of data entry. A verification summary will be generated and will be accessible by the EPA once the annual GHG emissions report is submitted.
 
Even though the IVT does not save the input data, the source is required to maintain records of the input data.  The IVT will prompt the user to save the data locally to their computer, but the burden to maintain the data is on the user.  Therefore, it is important to know where you save the data.

In addition, the IVT will time out after 25 minutes.  So, if you are interrupted while using the IVT, be sure to save the file locally so you can upload it later and continue working.  Otherwise, you will lose any work input into the IVT when it times out.

It’s all about the documentation

As with most environmental programs, claims of compliance are valid only 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 3 years.  However, facilities using the IVT must maintain records, including the input data you saved locally to your computer, for 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.

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