Trinity Consultants

MRR deadlines and updates

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Courtesy of Courtesy of Trinity Consultants

The U.S. EPA has made several changes to the Greenhouse Gas (GHG) Mandatory Reporting Rule (MRR) during the spring and summer of 2011. Reporters should be aware of the following reporting deadline and rule update.

  • Annual reports covering calendar year 2010 must be submitted via EPA’s electronic greenhouse gas reporting tool (e-GGRT) by September 30, 2011
  • EPA issued a final rulemaking regarding treatment of confidential business information
  • EPA modified the Best Available Monitoring Methods (BAMM) provisions for both Subpart W (Natural Gas and Petroleum Systems) and Subpart I (Electronics Manufacturing)
  • EPA proposed technical, clarifying and other amendments to several new subparts finalized in 2010

Annual Reporting
To prepare for the upcoming September 30 annual reporting deadline, reporters must consider the method they will report. EPA has provided two options for reporters, both using the e-GGRT system. Reporters must register in e-GGRT by August 1, 2011 if they are required to report 2010 emissions. There is no need to re-register if a reporter has already done so early in 2011; however, the e-GGRT hotline recommended that existing users log into the system to refresh their login if it has expired.

Reporters must choose whether they will manually enter the reportable data in e-GGRT for each applicable subpart, or if they will upload to the e-GGRT website a bulk XML file which contains all the required data elements. Trinity has developed an Excel-based tool which automatically generates XML code for Subparts A and C. Reporters may want to consider use of this automated tool for the following benefits:

  • Eliminates/minimizes errors in manual data entry
  • Automated process takes less time in subsequent reporting years
  • Use of tool does not require purchase of 3rd party software since it runs in Excel
  • User-friendly interface using tables in Excel
  • Can be used to speed the reporting for complex facilities that have multiple subparts including Subpart C

Confidential Business Information (CBI) Treatment in the Rule
In May, EPA issued a final rule for confidentiality determinations for data elements to be reported under 34 subparts. EPA grouped data elements into categories and generally made confidentiality determinations on a categorical basis. EPA then determined that emissions data, calculations and test methods are public information and will not be treated as confidential business information (CBI). However, EPA has not yet finalized CBI determinations for data that are “Inputs to Emission Equations”, nor does the final rule cover certain subparts finalized in 2010.

EPA made the following statements for CBI from direct emitters and suppliers:

  • For direct emitters, EPA’s final rule classifies emissions, data, calculation methods, and operating characteristics of affected units as public information, while production and throughput data and information on raw materials that are not inputs for emissions calculations will not be released
  • For suppliers, EPA said it will not release customer and vendor information, the amount and composition of materials received, and data on emissions factors

EPA included large tables of CBI determinations in a memo titled Final Data Category Assignments and Confidentiality Determinations for Part 98 Reporting Elements for each subpart and labeled each data element according to its CBI status.

It is unclear how EPA will handle the submittal of the data elements which are “Inputs to Emission Equations” by the September 30, 2011 deadline; however, EPA’s current XML schema and the e-GRRT sandbox testing website do not include these elements which is a good indicator that EPA will not request these “inputs to emission equations” be reported by September 30, 2011. For more information on the final confidential business information rule, see

Additional MRR Updates
On April 20, 2011, EPA signed a final rule that extends the deadlines for submitting best available monitoring method (BAMM) applications for Subpart W: Petroleum and Natural Gas Systems. It also extended the time period certain facilities with specific types of emissions sources would be granted automatic use of BAMM under Subpart W.

On June 20, 2011, EPA signed a proposed rule, also for Subpart W, to extend the time period covered facilities would be permitted to use BAMM during 2011 without submitting a request for approval. This proposal would also expand the list of emissions sources which may use BAMM during 2011 without submitting a request, AND extend the deadline for requesting BAMM beyond 2011. Since the deadlines differ depending on the emission source, refer to EPA’s Fact Sheet for exact dates: /documents/Subpart-W-BAMM-factsheet.pdf

On June 22, 2011, EPA issued a final rule for additional sources of fluorinated GHGs, extending three of the BAMM deadlines for electronics manufacturing (Subpart I) from June 30, 2011 to September 30, 2011. On the same day, EPA also proposed a rule to provide additional flexibility under Subpart I for the largest semiconductor facilities, allowing them the option to use default factors for certain sources for a limited time period.

Recently, on July 19, 2011 EPA proposed technical, clarifying and other amendments to the following subparts: A, W, FF, II, OO, RR, and TT. These amendments only apply to new subparts released in 2010 with first annual reports covering these subparts due in 2012. The proposed changes are meant to clarify and create consistency throughout all the emissions equations, and monitoring and reporting requirements.

In conclusion, a reporter preparing to submit their annual report covering 2010 emissions must consider which reporting method works best for their facility. If choosing the manual data entry option, consider whether you have sufficient resources to handle the process, whether you have gathered and documented all the required reporting elements so that e-GGRT data entry will flow smoothly, and whether you have used the aggregation provisions for combustion sources under Subpart C to minimize the amount of data required.

If choosing the bulk XML file upload option, consider whether you have the capability to generate XML code for all applicable subparts, whether it has been adequately tested with EPA’s e-GGRT sandbox website, and whether you have adequate resources to update the XML tool based on EPA’s final version of the XML schema. Consider using Trinity’s XML tool to generate Subpart C XML code, which can be merged and submitted with the XML code EPA’s e-GGRT system generates from manual data entry. Trinity can help facilities with submitting data under multiple subparts using this approach.

Regarding the confidentiality provisions, refer to EPA’s memo which explains which data elements can be considered CBI and stay tuned for developments regarding reporting “Inputs to Emission Equations” since EPA has not finalized the confidentiality provisions for these data elements.

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