Additional Requirements for the Next Round of GHG Reporting

In 2011 U.S. EPA deferred the requirement to report certain data elements in annual Greenhouse Gas (GHG) Inventory Reports required by 40 CFR Part 98 (the GHG Reporting Rule).  Because reporters expressed concerns that these data elements were Confidential Business Information (CBI), the requirement to report them was deferred to allow time for U.S. EPA to evaluate the potential impact of releasing this information to the public and make final determinations with regard to CBI status.  The data elements in question are inputs to equations that are required to be used to calculate reportable GHG emissions.  Reporting of some of these data elements was deferred until March 31, 2013, while reporting of others was deferred to March 31, 2015.

The data elements whose reporting deadline was deferred until 2013 (2013 inputs) include data elements used under the following subparts of Part 98:

• C (Stationary Fuel Combustion)
• D (Electricity Generation)
• DD (SF6 from Electrical Equipment Use)
• FF (Underground Coal Mines)
• HH (Municipal Landfills)
• II (Industrial Wastewater Treatment)
• SS (Electric T&D Equipment Manufacturing)
• TT (Industrial Waste Landfills)

U.S. EPA has completed its evaluation of the 2013 inputs and concluded that they were either already publicly available or are not the types of information that would allow competitors to gain competitive advantage if released to the public.  This means that, as far as U.S. EPA is concerned, the 2013 inputs are not CBI.  As a result, U.S. EPA does not plan to take any further action on the 2013 inputs and the deferral of the requirement to report them will expire.  A complete listing of the 2013 inputs and the rationale for the determination that they are not CBI can be found in U.S. EPA’s December 17, 2012 memo.

If you are subject to Part 98 and use any of the 2013 inputs to calculate GHG emissions, you will now be required to report them.  U.S. EPA will add input fields for the 2013 inputs into the Electronic Greenhouse Gas Reporting Tool (e-GGRT).  The next reporting period will run from mid-February until April 1, 2013.  During this reporting period you will not only be required to report the 2013 inputs for the current reporting year (2012), but will also be required to input this data from the past reporting years of 2010 and 2011, as applicable.  For reporting years 2013 and beyond, inputs whose deadline was deferred until 2013 will continue to be reported as part of annual report submission.

So as you prepare to have your next round of GHG Inventory Report data submitted, be sure to dust off those calculations from previous reporting years 2010 and 2011 and locate any of the equation inputs whose deadline was deferred until 2013.  e-GGRT will now be expecting to receive this information, and may not allow a complete report submission unless it is provided.