The 2013 submission deadline for 40 CFR 98, more commonly called “the Greenhouse Gas Reporting Rule,” is fast approaching. Unlike 2011 and 2012, in which the reporting deadlines were pushed back to September due to technology issues, this year the EPA requires reports be submitted by the March 31st date codified in the regulations.
In 2009, the U.S. EPA issued the Mandatory Reporting of Greenhouse Gases Rule in order to collect accurate information to inform future policy decisions. The rulemaking was a response to Congress’ Consolidated Appropriations Act of 2008, which authorized the EPA to require GHG emitters to inventory and report emissions. Details on who must report, what must be reported, and what technology should be used to monitor and collect GHG emissions data can be found at 40 CFR Part 98.
Greenhouse Gas Reporting Requirements
The first official reporting year for Greenhouse Gas emissions was 2011. A number of major industry sectors are subject to mandatory reporting, namely electric utilities, major manufacturers, the petrochemical industry, mines, and certain other facilities that produce at least 25,000 tonnes* per year of CO2 or CO2 equivalent emissions. A “CO2 equivalent” or “Co2e” value is calculated by determining the potential of an emitted greenhouse gas to contribute to global warming, as compared to carbon dioxide.
Facilities must report when GHG emissions exceed 25,000 tonnes of CO2e per year. The six major greenhouse gases are:
- Carbon dioxide (CO2)
- Methane (CH4)
- Nitrous oxide (N2O)
- Sulfur hexafluoride (SF6)
- Hydrofluorocarbons (HFCs)
- Perfluorocarbons (PFCs)
- And other fluorinated greenhouse gases defined at 40 CFR Section 98.6
The EPA’s complete list of facilities who must report includes those that meet the above criteria, as well as some others:
Submitting Reports Using the e-GGRT
- Any facility which is in a source category listed in 40 CFR 98.2(a)(1), regardless of the actual amount of GHGs emitted,
- Any facility which is in a source category listed in 40 CFR 98.2(a)(2), if it emitted 25,000 tonnes of CO2e gases or more in 2012,
- Any facility which does not meet the previous two criteria but has stationary combustion sources with a 30mmBTU/hr rating or greater, and which emitted 25,000 tonnes or more of CO2e gases in 2012 (per 40 CFR 98.2(a)(3)), or
- Greenhouse gas suppliers (40 CFR 98, Subparts LL through QQ).
Reports must be submitted electronically using the e-GGRT (Electronic Greenhouse Gas Reporting Tool)
. Paper submissions are not accepted. Facilities must register on the e-GRRT site and then submit the one-time Electronic Signature Agreement (ESA). Once the ESA is approved, registrants return to the e-GRRT site to complete registration and then be able to report. For first time submitters, the process of setting up an account for the e-GRRT system may take a few weeks, so do not wait until the March 1 deadline to register.
While research & development activities are not included in calculating emissions totals (40 CFR 98.2(a)(5)), in general once a facility meets the applicability under Part 98, it must continue to submit annual reports, even if it no longer meets the reporting thresholds. A facility can petition to cease annual reporting if it meets one of the following criteria:
- Emit less than 25,000 tonnes CO2e for five consecutive years,
- Emit less than 15,000 tonnes CO2e for three consecutive years, or
- Cease the GHG-emitting process / operations.
The facility must submit a written petition to the EPA by March 31 of the following year and must retain supporting records for at least three years. [40 CFR 98.2(i)]
What other difficulties do you face when filling out Greenhouse Gas Reports?
New Clean Air Act Regulations Now Available
A new online course is now available to help environmental engineers, EHS managers, and compliance officers keep their facilities in compliance with the US EPA’s Clean Air Act programs. The Clean Air Act Regulations
guides professionals through compliance with Title V permit requirements, emissions and pollution controls, annual greenhouse gas (GHG) reporting, Risk Management Planning (RMP) responsibilities, and more.
Build the expertise needed to make informed on-the-job decisions that help your site control pollution and maintain compliance. Interactive, easy to use, and available 24/7, the new online course will help you get up to speed with new and changing EPA clean air rules and protect your facility from costly EPA enforcement.
*1 tonnes, or metric ton, is equivalent to 2,204.6lbs.