The EPA has announced that it will aggregate confidential business information (CBI) reported under the Greenhouse Gas Reporting Program (GHGRP).  Aggregation will allow for CBI reported to the Agency to be publicly released without revealing the identity of the reporting entities or allowing others to use the data to obtain a competitive advantage.

The EPA said the primary purpose in aggregating GHG data is to improve information included in the Agency’s annual Inventory of U.S. Greenhouse Gas Emissions and Sinks, a comprehensive assessment of U.S. GHG emissions.  The EPA has a commitment to submit the Inventory to the United Nations Framework Convention on Climate Change (UNFCCC).

Noninputs to equations

Since introducing its GHGRP in 2009, the EPA has labored to meet its legal obligation to protect the confidentiality of certain information reported by the industrial sectors subject to the program.  Information warranting protection is vaguely described as data that are “not inputs to emission equations.”  At the same time, the integrity of the GHGRP depends on transparency in informing the public, building public confidence in the data, and ensuring data quality, all of which support the development of potential future climate policies or programs.

“The EPA believes that publication of aggregated GHGRP data helps to accomplish all of these goals,” says the Agency.

Aggregation is common

The EPA notes that both government agencies such as the U.S. Energy Information Administration (EIA) and industry organizations such as the American Petroleum Institute (API) routinely publish data in an aggregated format.  For example, the API collects natural gas liquid production and sales data from its members and publishes the aggregated data to the state and the Petroleum Administration for Defense District (PADD).

Four criteria

To determine whether a particular data element aggregated at the national or regional level may be published without risk of disclosing any facility- or supplier-level CBI, the EPA intends to assess data aggregation according to the following criteria.

• 1a.  The data used to calculate the aggregated value must be reported by at least three separate facilities or suppliers that have no common ownership or operator.
• 2a.  No single owner or operator can contribute more than x percent to a particular aggregated value. (The EPA will not disclose the value of x.)
• 3a.  No two owners or operators can contribute more than y percent of a particular aggregated value. (The EPA will not disclose the value of y.)
• 4a.  No underlying facility- or supplier-level CBI can be back-calculated or otherwise determined using the aggregated value in combination with other publicly available data, including any facility-, supplier-, regional-, or national-level data published by the GHGRP or any other data likely to be available to owners or operators.

Examples

The EPA says it will publish only aggregated values that meet all four criteria.

“Combined, the criteria ensure that publishing aggregated values that meet the criteria would not inadvertently disclose facility- or supplier-level CBI,” says the Agency.  “For example, if five facilities reported a particular data element and one company has part or total ownership of four of the five facilities, criterion 1a would not be met and the EPA would not release the aggregated value.  Similarly, if the data reported by one or two companies comprise the vast majority (greater than the value of x or y described above) of the aggregated value reported, then criteria 2a and 3a would not be met and the EPA would not release the aggregated data.  Finally, if other public data could be used in combination with the aggregated value to calculate or otherwise estimate CBI reported by a facility or supplier, criterion 4a would not be met.  For example, if a data element is aggregated by region and all but one regional aggregation meet the criteria, publishing the values from all of the other regions would allow the data for the final region to be back-calculated if the national total is also published.  In this case, the EPA would withhold data from at least one other region.”

EPA’s notice on aggregating CBI under the GHGRP was published in the June 9, 2014, FR.