Regulation Database – Greenhouse Gas Reporting Rule

Greenhouse Gas Reporting Program – Overview

Finalized by EPA in September 2009, the Greenhouse Gas Reporting Program (GHGRP) requires reporting of GHG emissions from large sources in the United States, and is intended to collect data to inform future policy decisions. Beginning in 2010, the rule requires suppliers and large sources across dozens of source categories to report GHG emissions. Parties subject to the rule include: suppliers of fossil fuels or industrial greenhouse gases, manufacturers of vehicles and engines, and facilities that emit 25,000 metric tons or more per year of GHGs. The gases covered are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFC), perfluorocarbons (PFC), sulfur hexafluoride (SF6), and other fluorinated gases including nitrogen trifluoride (NF3) and hydrofluorinated ethers (HFE). Reporters began monitoring in January 2010, and the first reports were due in March 2011 (later extended to September).

In administering the Greenhouse Gas Reporting Rule, EPA is engaged in an ongoing rulemaking process, including with technical amendments and with the expansion of the scope of sources required to report. Amendments to-date are reviewed below.

Rule Documents:

Electronic Reporting and Data

In August 2011, EPA opened a web-based application for electronic reporting of GHG emissions data, known as the Electronic Greenhouse Gas Reporting Tool (e-GGRT). Entities subject to the reporting rule use e-GGRT to submit their GHG reports.

Datasets, summaries, and highlights are publicly available on EPA’s website for the most recent available reporting year, with archived information available for previous years. The database allows users to sort information in a variety of ways, including by facility, location, industrial sector, and type of GHG emitted. This information can be used by communities to identify nearby sources of GHGs, help businesses compare and track emissions, and provide information to state and local governments.

EPA’s Facility Level Information on Greenhouse Gases Tool (FLIGHT) presents GHGRP data in an interactive map-based platform.

Source Amendments

Since 2009, EPA has expanded the scope of sources subject to the Greenhouse Gas Reporting Rule by adding emissions source categories and activities.

In July 2010, EPA made the following sources subject to the reporting rule: magnesium production, underground coal mines, industrial wastewater treatment, and industrial waste landfills. In November 2010, EPA added petroleum and natural gas systems to the program. In December 2010, EPA amended the rule to require reporting from additional sources of fluorinated greenhouse gases, including electronics manufacturing, fluorinated gas production, electrical equipment use, electrical equipment manufacture or refurbishment, and imports and exports of pre-charged equipment and closed-cell foams. In a separate filing on the same day, EPA required reporting for geologic sequestration and other underground injection of carbon dioxide.

Methodological, Technical, and Clarifying Amendments

EPA has amended the Greenhouse Gas Reporting Rule numerous times to improve the efficacy of the program with methodological and technical amendments.

Initial routine technical amendments were finalized in October and December 2010. Another round of such amendments was made in November and December 2011.

In February 2012, to more completely account for emissions of fluorinated heat transfer fluids (HTFs) from electronics manufacturing, EPA made amendments to the definition of HTFs and to the provisions to estimate and report emissions from HTFs.

In August 2012, EPA promulgated a rule correcting errors and providing greater clarity and flexibility for reporters in certain source categories: industrial waste landfills, petroleum and natural gas systems, fluorinated gas production, and electronics manufacturing. This rule also made certain deadline extensions and confidentiality determinations applicable to these source categories (see sections below concerning deadlines and confidentiality). In November 2013, EPA finalized a rule revising and clarifying the calculation and monitoring methodologies for the electronics manufacturing source category, and making confidentiality determinations for the reporting of the new and revised data elements.

Also in November 2013, EPA finalized another set of technical revisions, chiefly amending the table of global warming potentials (GWPs) under the GHGRP to revise GWP values for certain greenhouse gases. In November 2014, EPA promulgated another broad set of technical amendments for calculation, monitoring, and reporting of GHG data, as well as amendments specifically applicable to petroleum and natural gas systems. Both sets of amendments included applicable confidentiality determinations.

In December 2014, EPA amended provisions pertaining to global warming potentials and other methodological issues related to fluorinated gas, and accommodating confidentiality concerns for the fluorinated gas production source category.

In October 2015, EPA established new reporting requirements pertaining to certain activities in fossil fuel extraction, gathering, and transmission. In November 2016, EPA finalized new amendments for petroleum and natural gas systems, adding new monitoring and calculation requirements for detecting leaks from oil and gas equipment. Under both these sets of amendments, EPA established confidentiality determinations for new data elements.

In December 2016, EPA made amendments to provide certain new clarifications and technical revisions, and to facilitate streamlining and data quality and consistency. Under the amendments, the new provisions are variously phased in during 2017, 2018, and 2019.

Deadline Extensions

At various points EPA has extended reporting and other deadlines.

In March 2011, EPA extended the deadline for reporting data for the initial program year (2010) to September 30, 2011.

In April 2011, EPA extended by three months the deadline for petroleum and natural gas facilities to request authorization to use “best available monitoring methods” (BAMM) to measure and quantify certain categories of GHG emissions in place of the more restrictive methods ordinarily required. The rule also extended the period during which well owners and operators with certain emissions sources could use the alternate methods without prior approval. In June 2011, EPA granted a similar extension of BAMM deadlines for electronics manufacturers. In September 2011, EPA again granted extensions for both the petroleum/gas and electronics manufacturing sectors for BAMM use and requests. In May 2013, EPA moved the BAMM request deadline for petroleum and natural gas systems back from September 30 to June 30 for the future reporting year.

In August 2011, EPA issued a final rule deferring the reporting deadline for data elements that are used by direct emitter reporters as inputs to emission equations under the GHG reporting rule. The final rule deferred reporting certain inputs to emission equations until March 31, 2013 or March 31, 2015, applying to data regarded as commercially sensitive that could reveal trade secrets or other confidential information. EPA made a similar deferral in August 2012.

As noted above, certain deadline extensions were also made by EPA in the course of promulgating technical amendments.

Corporate Information; Commercial Sensitivity of GHG Data

In September 2010, EPA amended the reporting rule to require reporting companies to report their corporate parent companies as well as applicable North American Industry Classification System (NAICS) codes (fact sheet).

In May 2011, EPA promulgated an amendment granting confidential treatment to certain categories of GHG related data that are required to be submitted under the GHGRP  (fact sheet). The amendment made confidentiality determinations for thirty-four industry sectors covered by the reporting program. For the covered sectors, EPA extended confidential status to nine categories of data that must be reported by direct emitters of GHGs and eight categories that must be reported by fossil fuel and industrial gas suppliers; confidential data are not disclosed to the public. In August 2012, EPA acted again by finalizing confidentiality determinations for most data elements to be reported under nine remaining subparts of the GHGRP (fact sheet). As discussed above, EPA also made various confidentiality determinations in the course of promulgating technical amendments applicable to certain source categories.

In October 2014, EPA finalized changes to the reporting and recordkeeping requirements for certain source categories, providing for reporters to enter their data with a new Inputs Verification Tool, which conducts electronic verification checks. This accommodation addressed confidentiality concerns by allowing EPA to conduct verification without industry disclosure of certain inputs.

Noted above, certain deadline extensions were also made to accommodate commercially sensitive data.

A full overview of the EPA Rulemaking for Confidential Business Information in GHG Reporting is available here.

« Climate Regulation Database