May 12, 2011
The U.S. EPA’s regulation for reporting of greenhouse gases (GHG), or the Mandatory GHG Reporting Rule (40 CFR part 98), has undergone many changes since it was initially published on October 30, 2009. Key changes include the following:
A number of new subparts were finalized covering many additional industrial sectors such as natural gas and petroleum systems, electronics manufacturing, and industrial wastewater treatment
Technical amendments and clarifications were made affecting nearly every subpart
Draft provisions on handling confidential business data in annual reports were published
Multiple changes were made to the reporting deadline for calendar year 2010 emissions
Initially, EPA retained the original March 31, 2011 deadline for all reporters required to submit annual emissions reports covering calendar year 2010 activities. However, on December 27, 2010, EPA delayed a portion of the required data elements from being due by March 31, 2011, and issued a deferred reporting deadline for these certain data elements of August 31, 2011.
On March 1, 2011, these reporting deadlines were changed once again. The reporting deadline for calendar year 2010 reporters has been delayed until September 30, 2011. This delay will allow EPA sufficient time to adequately test the online reporting system, known as e-GGRT (electronic Greenhouse Gas Reporting Tool). The additional time will also give users the opportunity to test the system, provide feedback, and become familiar with the tool prior to the reporting deadline.
EPA plans to open e-GGRT’s reporting functionality later this summer. To date, the system has only been available to register users. EPA has not commenced with beta testing of the system, but expects to begin initial testing in mid-May 2011 for a two-week period. EPA is seeking detailed feedback on the design of e-GGRT during this time. By June, all reporters are expected to have an opportunity to test the reporting functionality of the tool. A second round of testing by reporters is expected to occur in August, after the final tool is released.
Reporters preparing to submit their annual emissions should be aware of the two reporting options EPA is allowing. The first option is to report annual emissions through manual data entry onto EPA’s web forms through e-GGRT. The second option is to use EPA’s XML reporting schema to upload GHG emissions directly into e-GGRT in lieu of using the web forms.
The XML reporting schema is a set of specifications that can be used to create an electronic data format (such as MS Excel) to upload directly into e-GGRT. The XML formatted tool is an automated approach to reporting, rather than manually keying emissions data into the web forms. To create an XML reporting tool, a reporter must use the XML reporting schema as a guidance document. On March 28, 2011, EPA released an updated version of the XML reporting schema. In this revision, EPA added in the deferred data elements that had previously been excluded from the reporting schema. Now that the reporting deadline is set for September 30, 2011, and all required data must be reported by this date, reporters should use the latest XML reporting schema in building an XML reporting tool. Reporters should also monitor EPA’s website for any further updates to the final XML reporting schema since it is subject to change prior to the September 30, 2011 deadline.
Trinity will continue to track developments on reporting deadlines and e-GGRT development for this regulation, If your facility needs assistance in developing an automated XML reporting tool, please contact Aimee Andrews, Managing Consultant at firstname.lastname@example.org or (919) 462-9693.