• GHG reporting is required for sources that emit 25,000 metric tons or more of CO₂ equivalent per year in the U.S.
• There are three type of greenhouse gas source categories “all-in”, threshold, and stationary fuel combustion sources.

The Environmental Protection Agency’s (EPA’s) 2009 Mandatory Reporting of Greenhouse Gases Rule at 40 CFR 98 requires large sources and suppliers to report their emissions of greenhouse gases (GHGs) to the EPA. The reporting program is called the Greenhouse Gas Reporting Program (GHGRP).

According to the EPA, more than 13,000 facilities in the U.S. are covered by the GHGRP.

Part 98

Part 98 is divided into 43 subparts. Subpart A lists the general reporting and recordkeeping requirements to apply to all facilities and suppliers subject to the rule. It also contains the applicability provisions, the reporting schedule, and definitions.

Subpart A also contains the overarching requirements of the rule. For example, there are flow meter accuracy and calibration provisions that apply when they are specified in a particular subpart. The specific types of monitoring equipment needed is defined in the source category subpart, however.

Subparts C through UU contain specific requirements for each of the source categories covered by the rule. The company must follow all the subparts that pertain to the facility. For example, if the facility produces adipic acid and has fuel combustion sources, the company needs to read subpart C, general stationary fuel combustion sources, and subpart R for adipic acid production.

Each subpart defines the specific source category it covers and lists the monitoring methods, equations to calculate emissions, and specific data elements to report or record for that source category.

Who’s covered?

40 CFR part 98 requires reporting by 41 industrial categories. Reporting is required for sources that emit 25,000 metric tons or more of carbon dioxide (CO₂) equivalent per year in the U.S. This includes 33 different types of direct emitters and six types of suppliers of fuel or industrial greenhouse gases. In addition, facilities that inject CO₂ underground for geologic sequestration, enhanced oil recovery, or other purpose are subject to mandatory GHG reporting.

Applicability for facilities depends on the source categories located at the facility and, for some facilities, the emission level or production capacity. Reporting is at the facility level except for certain suppliers of fossil fuels and industrial greenhouse gases.

The emissions reporting requirements for direct emitting facilities are found in 40 CFR 98.3(c)(4), and the emissions reporting requirements for suppliers are found in 98.3(c)(5)

A facility is defined as the physical property, plant, building, structure, source, or stationary equipment:

• On contiguous or adjacent properties;
• In actual physical contact or separated solely by public roadway or other public right of way; and
• Under common ownership or common control.

Once the company establishes the facility boundary, applicability depends on the source categories that are present. The rule defines three types of source categories:

• “All-in” source categories,
• Threshold categories, and
• Stationary fuel combustion sources.

If the company has multiple source categories on site, do not designate the facility as being a single source category (for example, based on determining the predominant operation). Rather, evaluate each source category to assess applicability. Keep in mind that a facility with multiple source categories can become subject to the rule because of just one category. But if the company is subject to the rule, then the GHG report must cover ALL source categories for which methods are provided in the rule — not just the source category that triggered applicability.