EPA’s latest set of proposed amendments to the greenhouse gas  reporting program (GHGRP) focus on revising the global warming potential (GWP) of some GHGs (primarily methane and fluorinated gases) and to add GWPs for certain fluorinated GHGs not currently listed in the GHGRP regulations.  The proposed GWP amendments align with information developed by the United Nation’s Intergovernmental Panel on Climate Change (IPCC).

Originally published in October 2009, the GHGRP covers facilities in dozens of industrial sectors that are required to either measure or estimate their GHG emissions and report the data annually to the EPA.  The rule and its frequent follow-up actions have prompted thousands of comments from the affected sectors to enlighten the Agency about technical considerations.  A table included in an EPA memorandum “summarizing” the current set of proposed amendments runs for over 80 pages.

Technical amendments

In addition to amending the GWP table in the GHGRP general provisions (Table A–1 of Subpart A Part 98), EPA’s proposed technical amendments include:

• Changes to clarify the applicability of calculation methods to certain sources at a facility;
• Corrections to terms and definitions in certain equations to provide clarity or better reflect actual operating conditions;
• Amending monitoring and quality assurance methods to provide flexibility for certain facilities;
• Corrections to data reporting requirements so that they more closely conform to the information used to perform emissions calculations; and
• Adding readily available data reporting requirements that would allow the EPA to verify the data submitted and assess the reasonableness of the data reported.

Since the data required to be reported would change under the proposed revision, the Agency is also proposing confidentiality determinations for the new or substantially revised reporting data elements.  The CAA prohibits confidentiality protections for inputs to emissions equations. 

184 new reporters

If finalized, the EPA says it expects the proposed GWP amendments to result in a collective increase in annual reported emissions from all subparts covered by the GHGRP of more than 104 million metric tons CO2e (a 1.4 percent increase in current emissions).  The EPA says it believes this change more accurately reflects the estimated radiative forcing from the emissions reported.  The increase would include 4.8 million metric tons CO2e from an estimated 184 additional facilities that would be newly required to report based on the new and revised GWPs.  According to the Agency, the majority of new reporters would be in Subpart W (petroleum and natural gas systems)–99; Subpart HH (municipal and solid waste landfills)–57; and Subpart TT (industrial waste landfills)–19.

The Agency says it expects to finalize the amendments before the end of 2013.  This means affected entities, including those newly included in the GHGRP under the proposed amendments, would need to file required reports that comply with the proposal by March 31, 2014.  

EPA’s latest set of proposed amendments to the GHGRP was published in the April 2, 2013, FR.