2012 GHG Reports Coming Due For Some, But Not All

When U.S. EPA established its Greenhouse Gas (GHG) Reporting Program under 40 CFR Part 98, the idea was for facilities under the program to submit annual reports of their GHG emissions by the end of March of each subsequent year.  In its first year, the program experienced delays and GHG emission inventory reports for reporting year 2010 ended up not being due until the end of September 2011.  Now that the second reporting year of 2011 has past, one could logically expect the GHG Reporting Program to pick up on its original annual schedule.  And it will . . . just not for everybody.

U.S. EPA continued to make additions and changes to its GHG Reporting Program throughout 2011.  As a result, for reporting year 2011 (January 1 through December 31, 2011), the annual report must include emissions from 12 new source categories that were not around for the 2010 reporting year, if they are located at your facility.  Since requirements for some of these new categories were not finalized until late into the 2011 reporting year, U.S. EPA has again extended the date in 2012 when reports are due . . . just not for everybody.  It turns out the reporting extension this time is only for those facilities that contain one of the new 2011 source categories.

The new 2011 source categories are as follows:

Subpart I – Electronics Manufacturing
Subpart L – Fluorinated Gas Production
Subpart T – Magnesium Production
Subpart W – Petroleum and Natural Gas Systems
Subpart DD – Use of Electronic Transmission and Distribution Equipment
Subpart FF – Underground Coal Mines
Subpart II – Industrial Wastewater Treatment
Subpart QQ – Imports and Exports of Certain Equipment Containing GHGs
Subpart RR – Geologic Sequestration of Carbon Dioxide
Subpart SS – Manufacture of Electronic Transmission and Distribution Equipment
Subpart TT – Industrial Waste Landfills
Subpart UU – Injection of Carbon Dioxide

So, some facilities will have to submit their 2011 reports soon.  But others, not-so-soon.  Basically, here’s how it works:

• If you submitted a GHG report for reporting year 2010 and you will NOT be reporting for any of the new 2011 source categories listed above, then your 2011 GHG report is due by April 2, 2012.  (Yes, April 2^nd, because March 31^st this year falls on a Saturday and the report is therefore due by the next business day.) 

• If you are required to report for any of the new 2011 source categories, then your entire facility GHG report for 2011 is not due until September 28, 2012.  But don’t relax just yet.  Because if your facility submitted a GHG report for reporting year 2010 under an existing source category, then before April 2, 2012 you must log on to U.S. EPA’s Electronic GHG Reporting Tool (e-GGRT) to notify U.S. EPA that you are not required to submit your report until September 28^th.