GHG report checklist: 5 C’s for the GHGRP
Each year, spring ushers in the season for green — budding trees, blooming plants, and the Greenhouse Gas Reporting Program (GHGRP). Okay, so the last item isn’t typically associated with thoughts of springtime. However, the March 31 deadline for the annual GHGRP report always springs up.
The GHGRP requires covered facilities, suppliers, and sites to submit an annual report of greenhouse gas (GHG) emissions data and other relevant information from the previous calendar year to the Environmental Protection Agency (EPA).
Although the reporting years change, the best practices for submitting accurate and timely reports don’t. Use the following checklist to help you comply with the GHG annual report requirements.
1. Confirm that you’re required to report.
The GHGRP generally applies to:
- Certain facilities that directly emit 25,000 or more metric tons of carbon dioxide equivalent (or CO2e) per year through combustion or processing on-site;
- Certain suppliers of fossil fuels, industrial GHGs, and GHG-containing products that result in GHG emissions when combusted, released, or oxidized; and
- Facilities that inject carbon dioxide (CO2) underground.
See 40 CFR 98.2 for the complete eligibility requirements that facilities, suppliers, and CO2 injectors must meet to be subject to the GHG annual reporting requirements.
2. Classify all relevant source categories.
The GHGRP groups reporters by specific industry types known as source categories. Each facility must report GHG emissions for all source categories that apply.
The subparts under Part 98 list the requirements for each source category, such as:
- Reporting thresholds,
- The GHGs to report,
- Calculation methods,
- Monitoring requirements, and
- Data reporting requirements.
For example, Part 98 Subpart Q lists the reporting requirements for the Iron and Steel Production category, while Part 98 Subpart MM lists the requirements for the Suppliers of Petroleum Products category.
Tables A-3, A-4, and A-5 under Part 98 Subpart A list the source categories and any specific reporting thresholds.
3. Calculate emissions with approved methodologies.
Reporters must use specific methodologies established in the regulations to determine GHG emissions from each source category. The subparts under Part 98 contain the approved calculation methodologies for each source category and generally include several options.
If you meet the method’s requirements, you can change emission calculation methods from year to year and within the same year.
4. Choose the designated representative.
A designated representative is the individual responsible for submitting the GHG reports on behalf of the owners and operators of the facility or supplier. The regulations at 98.4 allow (but don’t require) the designated representative to appoint an alternate designated representative and one or more agents who can act on their behalf.
EPA will not accept annual GHG emissions reports from a facility or supplier without a Certificate of Representation for a designated representative. This certificate must be submitted at least 60 days before the initial annual GHG emissions report deadline.
5. Create and prepare the reporting account ahead of time.
The GHG annual report is submitted electronically through EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT). To submit the annual report, you must first register as an e-GGRT user and create an account. If you already have an active EPA Central Data Exchange (CDX) account, log into e-GGRT with your existing CDX username and password. If you don’t have a CDX account or cannot log in with those credentials, create a new user account on e-GGRT.
All e-GGRT users must have the Electronic Signature Agreement (ESA) on file with EPA. You can electronically sign the agreement or submit a signed hard copy. Once EPA approves the agreement, the agency will send you an account activation notice, and you can begin registering a facility and the designated representative.
The designated representative must register as an e-GGRT user and, once EPA approves the representative’s ESA, accept the appointment as the designated representative and electronically sign the Certificate of Representation. The certificate allows the representative to certify, sign, and submit the annual GHG report to EPA. Resubmission of the certificate is required only when there are updates to the facility profile or information about the designated representative changes (including replacing the existing representative).
Key to remember: Annual reports for the Greenhouse Gas Reporting Program are due by March 31 and require reporters to include emissions data from all applicable source categories.
