10 Things to Know About the GHG Reporting Program
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1) The GHG Reporting Program covers only specific emissions. Only man-made (or anthropogenic) GHG emissions covered under the United Nations Framework Convention on Climate Change (UNFCCC) must be reported. These are:
- Carbon dioxide (CO2),
- Methane (CH4),
- Nitrous oxide (N2O),
- Hydrofluorocarbons (HFC),
- Perfluorocarbons (PFC),
- Sulfur hexafluoride (SF6), and
- Other fluorinated GHGs. Specifically, the Environmental Protection Agency (EPA) defines “fluorinated GHGs” as “sulfur hexafluoride (SF6), nitrogen trifluoride (NF3), and any fluorocarbon except for controlled substances as defined at 40 CFR Part 82, Subpart A and substances with vapor pressures of less than 1 mm of Hg absolute at 25 degrees C. With these exceptions, “fluorinated GHG” includes but is not limited to any hydrofluorocarbon, any perfluorocarbon, any fully fluorinated linear, branched or cyclic alkane, ether, tertiary amine or aminoether, any perfluoropolyether, and any hydrofluoropolyether.”
Attend the March 31 GHG Emissions Report Deadline webinar on February 26 to ensure that your GHG report filing is legally compliant. Learn more.
2) The GHG reporting rule may impact some small businesses. Although the reporting threshold of 25,000 or more metric tons of CO2 equivalent (mtCO2e) emissions per year excludes most small businesses, the EPA concedes that “Some small businesses in energy-intensive industries or heavy manufacturing sectors may need to report…,” with the exclusion that “The reporting requirements related to vehicle and engine emission rates do not apply to manufacturers treated as ‘small businesses’ or ‘small-volume manufacturers’ under EPA’s existing mobile source emission regulations.”
3) There are some sectors where every facility must report, even if an individual facility does not meet the 25,000 mtCO2e emissions threshold. For some of the source categories, all of the facilities that have that particular source category within their boundaries will be subject to the rule. According to the EPA, this is because their analysis indicated that “all or nearly all facilities with that source category emit more than 25,000 mtCO2e per year, and that an ‘all in’ would simplify their applicability determination.” These source categories include large manufacturing operations such as petroleum refineries and cement production. A complete breakout of source categories is available at www.epa.gov/ghgreporting/documents/pdf/infosheets/generalprovisions.pdf.
March 31 GHG Emissions Report Deadline: Strategies for Filing Success and Best Practices for Data Collection
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4) In addition to facilities, certain suppliers of fossil fuels and industrial GHGs must also report. Suppliers of the following fossil fuels must report the annual quantities of fuels supplied into the economy and the emissions associated with the complete oxidation of the fuels:
- Coal-based Liquid Fuels: All producers and importers and exporters above a threshold;
- Natural Gas and Natural Gas Liquids: All natural gas fractionators and all local distribution companies; and
- Petroleum Products: All producers and importers and exporters above a threshold.
Suppliers of the following industrial GHGs must report the annual quantities of each gas supplied into the economy and the emissions associated with their complete release:
- Fluorinated Gases: All producers and those importers or exporters above a threshold;
- Nitrous Oxide: All producers and those importers or exporters above a threshold; and
- Carbon Dioxide: All producers and those importers or exporters above a threshold.
5) GHG emissions reported by suppliers help the EPA account for emissions from small businesses that do not meet the reporting threshold. While the majority of facilities required to report are large facilities that meet the 25,000 mtCO2e per year threshold, many small businesses also have emissions that are not reported by them. To avoid placing the reporting burden on small businesses, the EPA chose instead to track their emissions through data provided by suppliers, which also fulfills the congressional request that the EPA “collect data on greenhouse gas (GHG) emissions from both upstream production and downstream sources, as appropriate.” In turn, this allows the EPA to have all the GHG emissions data necessary for developing climate change policy and programs.