MEMORANDUM

TO:	Docket ID. No EPA-HQ-OAR-2019-0424
FROM:	Jennifer Bohman, OAR/OAP
DATE:	May 2023
SUBJECT: 	Assessment of Burden Impacts for Proposed Supplemental Notice of Revisions for the Greenhouse Gas Reporting Rule
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Introduction
This memorandum explains how reporters will be affected by the proposed Supplemental Notice of Revisions and Confidentiality Determinations for Data Elements Under the Greenhouse Gas Reporting Rule and presents the impacts of the revisions to reporters. The memorandum is organized as follows:
       Section 2.0:	Background for Proposed Amendments and Proposed Methodology
       Section 3.0:	Summary of Burden Impacts
       Section 4.0:	Small Entity Impacts
      Appendix A:   Revisions and Burden Impacts for Proposed Supplemental Technical Revisions for the Greenhouse Gas Reporting Rule
       Appendix B: 	Burden Estimates by Subpart (Excel File)

Background for Proposed Amendments and Proposed Methodology
Under the Greenhouse Gas Reporting Rule (40 CFR Part 98) facilities must report   emissions and emissions-related data to EPA through the electronic Greenhouse Gas Reporting Tool (e-GGRT). This analysis identifies the burden associated with proposed amendments to specific provisions of the Greenhouse Gas Reporting Rule. On June 21, 2022, EPA proposed amendments to specific provisions of the Greenhouse Gas Reporting Program (GHGRP). Since presenting the proposed amendments, the EPA has received or identified new information to inform additional amendments that would further improve the GHGRP and has developed a supplemental proposal. The purpose of the supplemental amendments is to improve the accuracy, completeness, quality, and consistency of the data collected, and streamline, clarify or correct specific provisions.
EPA is proposing to implement the revisions with reports submitted for RY2025. This document describes the increase or decrease in burden for each subpart and the total incremental burden of the proposed changes, as well as EPA's methodology for estimating burden impacts. This document also describes the methodologies used to estimate the impacts of the proposed changes.
The following types of proposed amendments are anticipated to potentially have a quantifiable effect on burden for the specified subparts by revising the number of facilities that need to report or increasing the amount of data that need to be monitored, recorded, and reported:
       Revisions That Affect Applicability or Reporting Thresholds for Certain Industry Sectors:
             Updates to the global warming potential (GWP) values in Table A-1 to subpart A. Revisions to GWPs from the IPCC AR5 including new GWPs for 31 new individual fluorinated GHG (F-GHG), revising GWPs for individual GHGs (including methane (CH4) and nitrogen oxide (N2O)), and revising default GWPs for several of F-GHG groups.
             Addition of new source categories. Revisions to expand Part 98 source categories to include energy consumption, coke calciners; calcium carbide production; caprolactam, glyoxal, glyoxylic acid production; and ceramics production.
             Subpart-specific amendments to applicability. Revisions to the applicability criteria of certain subparts, e.g., subpart P (Hydrogen Production) and subpart Y (Petroleum Refineries), to clarify and resolve gaps in coverage.
       Revisions to Monitoring and Calculation Methodologies: Revisions to improve existing emissions calculations methodologies, e.g. subpart AA (Pulp and Paper Manufacturing) and subpart HH (Municipal Solid Waste Landfills) to improve the accuracy of emissions estimates and resolve gaps in emissions coverage.
       Revisions to Reporting and Recordkeeping Requirements: Includes revisions to modify or refine calculation methodologies that result in revisions to reported data elements or data entered into EPA's Inputs Verification Tool (IVT); additions to reported data element requirements to improve the quality of the data that are currently reported, or to collect more useful data that would improve verification of reported data; revisions to expand reporting to include additional emissions or new emission sources for specific sectors to improve the accuracy and completeness of the data provided by the GHGRP and to address potential gaps in reporting (subparts A, C, F, G, N, P, Y, AA, HH, OO, PP, and QQ).
A number of amendments are technical corrections and clarifications that would have a minimal change in burden, are not quantifiable, or have no impact on burden, including minor technical amendments, clarifications, and corrections, such as editing and harmonizing requirements to improve the public's understanding of the rule (subparts A, I, AA, RR, UU, and VV).
The proposed revisions, if finalized, would be implemented in RY2025. The burden was subsequently determined based on implementation over the next three years. Sections 2.1 through 2.5 provide the methodology for estimating cost impacts for amendments with quantifiable burden reduction or increase. Section 2.6 describes the expected impacts of the revisions with no substantive increase in burden. Appendix A of this document provides a more detailed summary of the revisions to each subpart and the anticipated impacts from each proposed change.
The following Table 2-1 summarizes the source categories and associated subparts affected by the different types of changes being proposed, which are summarized in sections 2.1 through 2.6 of this document.
          Table 2-1. Summary of Subparts Affected by Proposed Changes
                      Part 98 Subpart and Source Category
          Revisions that Affect Applicability or Reporting Thresholds
                    Revisions to Monitoring or Calculations

                          Reporting and Recordkeeping

                Other Technical Corrections and Clarifications

                             Updates to Table A-1
                             New Source Categories
                        Other Changes to Applicability

                                  Section 2.1
                                  Section 2.2
                                  Section 2.3
                                  Section 2.4
                                  Section 2.5
                                  Section 2.6
Subpart A  -  General Provisions
                                       X

                                       X
                                       X
Subpart B  -  Energy Consumption

                                       X

Subpart C  -  General Stationary Fuel Combustion Sources

                                       X

Subpart F  -  Aluminum Production

                                       X

Subpart G  -  Ammonia Manufacturing

                                       X

Subpart I  -  Electronics Manufacturing

                                       X
Subpart N  -  Glass Production

                                       X

Subpart P  -  Hydrogen Production

                                       X

                                       X

Subpart V  -  Nitric Acid Production
                                       X

Subpart W  -  Petroleum and Natural Gas Systems
                                       X

Subpart Y  -  Petroleum Refineries

                                       X

                                       X

Subpart AA  -  Pulp and Paper Manufacturing

                                       X
                                       X
                                       X
Subpart DD  -  Electrical Transmission and Distribution Equipment Use
                                       X

Subpart HH - Municipal Solid Waste Landfills
                                       X

                                     X[*]
                                       X
                                       X

Subpart II  -  Industrial Wastewater Treatment
                                       X

Subpart OO  -  Suppliers of Industrial Greenhouse Gases
                                       X

                                       X

Subpart PP  -  Suppliers of Carbon Dioxide

                                       X
                                       X
Subpart QQ  -  Importers and Exporters of Fluorinated Greenhouse Gases Contained in Pre-Charged Equipment or Closed-Cell Foams

                                       X

Subpart RR  -  Geologic Sequestration of Carbon Dioxide

                                       X
Subpart TT  -  Industrial Waste Landfills
                                       X

Subpart UU  -  Injection of Carbon Dioxide

                                       X
Subpart VV  -  Geologic Sequestration of CO2 With Enhanced Oil Recovery Using ISO 27916

                                       X
Subpart WW  -  Coke Calciners

                                       X

Subpart XX  -  Calcium Carbide Production

                                       X

Subpart YY  -  Caprolactam, Glyoxal, and Glyoxylic Acid Production

                                       X

Subpart ZZ  -  Ceramics Production

                                       X

*The EPA is not proposing direct changes to the source definition or the applicability of subpart HH. However, EPA is proposing changes to Equation HH-7 of Subpart HH, which is used to determine methane generation from landfills with gas collection systems for comparison against the 25,000 mtCO2e threshold. Therefore, this analysis evaluates the potential for the proposed revisions to Equation HH-7 to cause a landfill to exceed the reporting threshold.

As discussed further in the preamble to this proposed rule, CAA section 114(a)(1) provides the EPA broad authority to require the information proposed to be gathered under these proposed revisions to part 98 because such data would inform and are relevant to the EPA's carrying out a wide variety of CAA provisions.
The proposed supplemental revisions would maintain the quality of the data collected under part 98 where continued collection of information assists in evaluation and support of EPA programs and policies. In some cases, the proposed amendments would improve the EPA's ability to assess compliance by revising or adding recordkeeping or reporting elements that allow the EPA to more thoroughly verify GHG data and understand trends in emissions. The proposed amendments would also advance the ability of the GHGRP to provide access to quality data on GHG emissions by adding new source categories to address potential gaps in reporting of emissions data for specific sectors, adding or revising calculation methodologies to reflect an improved understanding of emissions sources and end uses, or adding key data elements to improve the usefulness of the data.
The proposed supplemental revisions to part 98 include requirements for reporting of GHG data from additional sectors (coke calcining; ceramics production; calcium carbide production; and caprolactam, glyoxal, and glyoxylic acid production), improvements to emissions estimation methodologies, and collection of data to support verification of GHG emissions and supply. The proposed supplemental revisions would significantly improve the EPA's understanding of national emissions sources and trends and would better reflect changes across U.S. GHG emissions and supply. The proposed rule would additionally require collection of energy consumption data from direct emitters of GHGs, which would be used to inform the EPA's understanding of energy intensity. Finally, the proposed supplemental revisions would include updates to global warming potentials and improvements to emissions estimation methodologies, which would reflect a more current scientific understanding of GHGs and improve the quality of the data collected under the program.

 2.1 Updates to Global Warming Potential (GWP) Values
Proposed revisions to subpart A Table A-1 GWP values. The GWPs in Table A-1 of subpart A are primarily used for threshold calculations to determine rule applicability (40 CFR 98.2(b)) and for reporting total GHG emissions or supply in CO2e for each facility or supplier (40 CFR 98.3(c)(4)). Revisions to the GWPs in Table A-1 to Subpart A affect the calculation of facility emissions in CO2e, and thus any increase in the GWPs in a threshold analysis could cause a given facility or supplier to exceed the emissions reporting threshold, even if the facility did not previously exceed the threshold. A change to a facility's reporting status would cause the facility to incur costs for monitoring, recordkeeping, and reporting emissions.
Similarly, an increase in the GWPs in Table A-1 to Subpart A could also cause a given facility or supplier to be required to report after previously "off-ramping" from the GHGRP. The provisions at 40 CFR 40 CFR 98.2(i)(1) and (2) allow facilities to stop reporting to the GHGRP (or "off-ramp") if the total facility-level emissions are less than 25,000 metric tons CO2e per year for five consecutive years or less than 15,000 metric tons CO2e per year for three consecutive years. However, per 40 CFR 98.2(i), facilities that have ceased reporting must resume if annual emissions in any future calendar year increase to 25,000 metric tons CO2e per year or more. Additionally, certain facilities may become eligible to cease reporting through the GHGRP, in cases where specific GWPs have decreased, and facility reported emissions would fall below the thresholds in 40 CFR 98.2(i)(1) and (2).
In this memorandum, the impacts of the revised GWPs in Table A-1 to subpart A are evaluated for facilities that would be newly required to report under each subpart, would be required to restart reporting under a subpart if the facility had previously off-ramped, or would be able to cease reporting earlier. The compliance costs that would be incurred or saved by these new reporters are then estimated.
2.1.1 Identifying Affected Reporters
Reporters that would be affected by the proposed changes to Table A-1 of Subpart A were identified by considering 1) "all-in" direct emitter subparts (listed in Table A-3 of Subpart A of Part, in which all facilities that meet the source category definition must report) 2) "threshold" direct emitter subparts (listed in Table A-4 of Subpart A of Part 98 and that meet the 25,000 mtCO2e threshold in 40 CFR 98.2(b)), and 3) supplier subparts (Table A-5 of Subpart A of Part 98) that meet the following criteria:
 The subpart requires reporting of non-combustion "emissions" of CH4 or N2O, or F-GHGs. Changes to CH4 and N2O combustion emissions are assumed negligible due to an increase in the CH4 GWP and a decrease in the N2O GWP.
 The subpart requires reporting of "quantity of GHG supplied" for CH4, N2O, or F-GHGs.
 There is reason to believe there are facilities in the subpart that are below or near the 25,000 metric ton (mt) CO2e threshold.
Subparts that only require reporting of CO2 process emissions or CO2 supply would not be impacted by the proposed changes. Subparts only containing combustion emissions, or which include reporting of CH4/N2O as emitted together as combustion effluent, were not anticipated to be impacted, as the proposed changes to Table A-1 are expected to result in negligible decreases for these gases. The EPA therefore evaluated impacts to reporters subject to subparts E, F, I, K, L, O, T, V, W, DD, FF, HH, II, OO, QQ, SS, and TT. Additional information regarding how affected subparts were identified based on the proposed changes to GWPs in Table A-1 may be found in the memorandum "Facilities Potentially Impacted by the Proposed GWP Revisions to Table A-1 (Global Warming Potentials)", available in the docket to the rulemaking (Docket Id. No. EPA-HQ-OAR-2019-0424). Affected reporters were subsequently identified in subparts  V, W, DD, HH, II, OO, and TT. Sections <IP_ADDRESS> through <IP_ADDRESS> of this document provide additional details on the number of affected reporters in subparts V, W, DD, HH, II, OO, and TT.
<IP_ADDRESS> Subpart V

      The number of affected reporters subject to subpart V of Part 98 were identified in the memorandum "Facilities Potentially Impacted by the Proposed GWP Revisions to Table A-1 (Global Warming Potentials)" located in the docket to the rulemaking, EPA-HQ-OAR-2019-0424. As discussed in the memorandum, the burden for subpart V related to the proposed changes in GWPs is assumed to include one facility that may potentially meet the offramp provisions of 40 CFR 98.2(b) and stop reporting. There are no new facilities anticipated to begin reporting under subpart V and there are no existing facilities who have previously reported under subpart V that would be required to resume reporting following the proposed changes.
<IP_ADDRESS> Subpart W

      The number of affected reporters subject to subpart W of Part 98 were identified in the memorandum "Facilities Potentially Impacted by the Proposed GWP Revisions to Table A-1 (Global Warming Potentials)" located in the docket to the rulemaking, EPA-HQ-OAR-2019-0424. For Subpart W, the revisions to Table A-1 included in this supplemental proposal and the revisions included in the 2022 Data Quality Improvements Proposal would increase the number of facilities subject to the requirements of the GHGRP.  Some facilities would become subject to the requirements of the GHGRP due to either of these proposed changes.  EPA anticipates issuing a separate proposed rulemaking to implement certain provisions of the Methane Emissions and Waste Reduction Incentive Program that would propose further revisions to the requirements of Subpart W and which could also change the number of facilities subject to this subpart. The estimate included here for Subpart W in this supplemental proposal conservatively includes all facilities that would become subject to the GHGRP due to the proposed changes to Table A-1 included in this supplemental proposal compared to the existing requirements of the GHGRP.  This estimate does not consider revisions proposed under the 2022 Data Quality Improvement Proposal. As discussed in the memorandum, the burden for subpart W related to the proposed changes in GWPs is assumed to include 188 facilities that may potentially be required to report under certain industry segments as follows:

                          Subpart W Industry Segment
               Number of new subpart W sources due to GWP change
Gathering and Boosting
                                       0
Transmission Compression
                                      130
Onshore Production
                                      40
Underground Storage
                                       9
Natural Gas Distribution
                                       0
Transmission Pipeline
                                       1
Gas Processing
                                       0
LNG Storage
                                       1
LNG Import & Export
                                       0
Offshore Production
                                       7
TOTAL
                                      188

<IP_ADDRESS> Subpart DD

      The number of affected reporters subject to subpart DD of Part 98 were identified in the memorandum "Facilities Potentially Impacted by the Proposed GWP Revisions to Table A-1 (Global Warming Potentials)" located in the docket to the rulemaking, EPA-HQ-OAR-2019-0424. As discussed in the memorandum, the burden for subpart DD related to the proposed changes in GWPs is assumed to be two existing reporters that would no longer qualify for the off-ramp and would be required to continue reporting. There are no new facilities anticipated to begin reporting under subpart DD and there are no existing facilities who have previously reported under subpart DD that would be required to resume reporting following the proposed changes.
<IP_ADDRESS> Subpart HH

      The number of affected reporters subject to subpart HH of Part 98 were identified in the memorandum "Facilities Potentially Impacted by the Proposed GWP Revisions to Table A-1 (Global Warming Potentials)" located in the docket to the rulemaking, EPA-HQ-OAR-2019-0424. As discussed in the memorandum, the burden for subpart HH related to the proposed changes in GWPs is assumed to be 5 open landfills that have previously off-ramped from the GHGRP that may have to resume reporting due to the changes to the GWP and Table HH-1, and one open landfill that is anticipated to become a new reporter due to the changes to the GWP and Table HH-1, that would otherwise not have to report. There were no identified closed landfills that have never reported, and no closed landfills that have previously off-ramped, that would have to report again due to the new changes.
<IP_ADDRESS> Subpart II

      The number of affected reporters subject to subpart II of Part 98 were identified in the memorandum "Facilities Potentially Impacted by the Proposed GWP Revisions to Table A-1 (Global Warming Potentials)" located in the docket to the rulemaking, EPA-HQ-OAR-2019-0424. As discussed in the memorandum, the burden for subpart II related to the proposed changes in GWPs is assumed to be two new reporters who would be expected to start reporting to the GHGRP. There were no reporters identified as able to offramp as a result of the proposed changes, and no identified previously off-ramped reporters who would be required to resume reporting under the GHGRP.
<IP_ADDRESS> Subpart OO

      The number of affected reporters subject to subpart OO of Part 98 and affected by the proposed updates to the GWPs in Table A-1 of subpart A were identified in the memorandum "Facilities Potentially Impacted by the Proposed GWP Revisions to Table A-1 (Global Warming Potentials)". As discussed in the memorandum, the burden for subpart OO related to the proposed changes in GWPs is assumed to be one new reporter who would be expected to start reporting to the GHGRP. There were no reporters identified as able to offramp as a result of the proposed changes, and no identified previously off-ramped reporters who would be required to resume reporting under the GHGRP.
<IP_ADDRESS> Subpart TT

      The number of affected reporters subject to subpart TT of Part 98 and affected by the proposed updates to the GWPs in Table A-1 of subpart A were identified in the memorandum "Burden Evaluation Approach and Results Following Adoption of New GWPs for Subpart TT," included in the docket to the rulemaking, EPA-HQ-OAR-2019-0424. As discussed in the memorandum, the burden for subpart TT related to the proposed changes in GWPs is assumed to be one new reporter who would be expected to start reporting to the GHGRP. There were no reporters identified as able to offramp as a result of the proposed changes, and no identified previously off-ramped reporters who would be required to resume reporting under the GHGRP.

2.1.2 Estimating Cost Impacts
The cost impacts to reporters affected by the proposed updates to the GWPs in Table A-1 of subpart A were calculated by multiplying the average reporting costs by the number of affected reporters, as identified in section 2.1.1 of this document. The number of affected reporters may include:
 New reporters that subject to a subpart of Part 98 for the first time who would be subject to new burden;
 Reporters that have previously reported to and subsequently off ramped from the GHGRP, but that would be required to resume reporting and would be subject to new burden;
 Existing reporters that were anticipated to off-ramp within the next three years, but who would no longer qualify to off-ramp and would be required to continue reporting who would be subject to continued burden; or
 Existing reporters that are estimated to newly meet the offramp provisions who would no longer be required to submit a report under the GHGRP. These reporters would be anticipated to have a decrease in burden.
Appendix H to the most recent information collection request (ICR) for the GHG reporting program (OMB control number 2060-0629; ICR number 2300.18, available at www.reginfo.gov) was used to obtain the first year and subsequent year average labor burden that is incurred from reporting under each subpart. The average burden per facility includes labor costs (i.e., the hours and associated cost of labor by facility staff to meet the rule's information collection requirements) and non-labor (capital, and operation and maintenance (O&M)) costs. Facility labor burden includes labor hours for the following activities: planning, QA/QC, sampling and analysis and conducting calculations, recordkeeping, and reporting. To estimate labor costs, the average labor hours from Appendix H for each activity were multiplied by labor costs, using updated labor rates from the Bureau of Labor Statistics (May $2021). Labor costs were then adjusted to account for burden estimated in the June 21, 2022 proposed rule, adjusted to $2021. See Appendix A to this document for additional detail on the labor categories and labor rates referenced.
      Non-labor costs include capital and O&M costs such as the cost to store records, such as a flash drive, paper file or cloud storage, as well as sampling and analysis costs (e.g., costs associated with collecting and analyzing samples to determine carbon content). Appendix H to the most recent information collection request (OMB control number 2060-0629; ICR number 2300.18) was used to obtain the average non-labor costs that is incurred under each subpart. Non-labor costs were adjusted for inflation ($2021) using 2021 Chemical Engineering Plant Cost Index (CEPCI) annual values. Non-labor costs were also adjusted to account for costs estimated in the June 21, 2022 proposed rule, adjusted to $2021, where applicable.
      Sections <IP_ADDRESS> through <IP_ADDRESS> of this document summarize the change in burden for reporters in each of the 7 subparts that could be affected by the proposed changes to GWPs in Table A-1 of subpart A of part 98 (subparts V, W, DD, HH, II, OO, and TT).
<IP_ADDRESS> Subpart V

      The change in burden for subpart V is estimated by assuming one facility, currently reporting under Subpart V, would meet the offramp provisions of 40 CFR 98.2(b) and stop reporting within the next three years. That facility would experience a savings. The calculated savings were based on avoided labor costs (i.e., the cost of labor by facility staff to plan, keep records, gather and analyze performance tests, and submit information via e-GGRT) and the avoided capital and operation and maintenance costs associated with performance testing. The estimated savings are ($2,680) per year. Additionally, the reporter will having an O&M costs savings of ($11,085) per year ($2021), which includes costs saved on performance testing and records storage. See Appendix B, worksheet "Subpart V (Applicability)" for additional information. The other facilities reporting under Subpart V would have no change in burden.
<IP_ADDRESS> Subpart W

      For subpart W, the burden was estimated based on the assumption that 188 facilities would be required to newly report, including 130 facilities in the Natural Gas Transmission Compression segment, 40 facilities in the Onshore Production segment, 9 facilities in the Underground Natural Gas Storage segment, one facility in the Natural Gas Transmission Pipeline segment, one facility in the Liquified Natural Gas Storage segment, and 7 facilities in the Offshore Production segment. The burden for these reporters was estimated by determining initial year and subsequent year labor hours and capital and O&M costs from Appendix H of ICR No. 2300.18, adjusted to $2021, for each industry segment. Capital and O&M costs from ICR No. 2300.18 include costs for gas sampling and analysis, the costs of simulation software, and other sampling or testing costs based on equipment type. The labor costs from ICR No. 2300.18 were adjusted to account for costs from the June 21, 2022 proposed rule, including burden from reporting new or revised data elements for each affected segment, as well as labor and non-labor costs associated with revisions to monitoring and calculation methods for each segment, adjusted to $2021. Non-labor costs from the 2021 proposed rule include testing costs for acid gas removal vents. The annual estimated burden from implementation of the proposed revisions for the new reporters is as follows:
                                    Segment
                           Change in Facility Count
                  Total Costs (2021$) for All New W Reporters

                                 Burden (hrs)
                                     Labor
                                    O&M
                                     Total
Gathering and Boosting
                                       0
                                       -
                             $                   -
                            $                    -
                           $                      -
LNG Import/Export
                                       0
                                       -
                             $                   -
                            $                    -
                           $                      -
LNG Storage
                                       1
                                     71.30
                              $            7,815
                              $             6,897
                             $             14,712
Natural Gas Distribution
                                       0
                                       -
                             $                   -
                            $                    -
                           $                      -
Natural Gas Processing
                                       0
                                       -
                             $                   -
                            $                    -
                           $                      -
Natural Gas Transmission Compression
                                      130
                                   10,034.38
                               $       1,102,879
                              $         2,392,078
                             $          3,494,958
Natural Gas Transmission Pipelines
                                       1
                                     75.36
                              $            8,323
                            $                   62
                             $               8,385
Offshore Production
                                       7
                                    269.48
                               $          29,974
                             $                 437
                             $             30,410
Onshore Production
                                      40
                                   12,575.70
                                $    1,399,157
                              $             8,239
                               $       1,407,395
Underground Natural Gas Storage
                                       9
                                    659.72
                               $          72,271
                               $         310,150
                              $          382,421
Total
                                      188
                                    23,686
                                $    2,620,418
                              $         2,717,864
                               $       5,338,282

      		To estimate an individual reporter burden for new W reporters, the weighted average burden from implementation of the proposed revisions for all segments was estimated (weighted by the number of affected reporters in each segment). These costs were estimated at $28,395 per facility in both the first and subsequent years, including $13,938 in labor costs and $14,457 in capital and O&M costs. See Appendix B, worksheet "Subpart W (Applicability)" for additional information.
<IP_ADDRESS> Subpart DD

      For proposed subpart DD, the burden was estimated based on the assumption that two existing reporters that would no longer qualify for the off-ramp and would be required to continue reporting. The estimated burden for these existing reporters is consistent for years one through three. Each year, these reporters would continue to incur labor and O&M costs. Specific labor costs include time to become familiar with changes to the rule requirement and time to collect and oversee sampling data. Labor costs were also adjusted to account for burden from reporting new or revised data elements as estimated in the June 21, 2022 proposed rule, adjusted to $2021 (adding $98 per reporter). O&M costs include independent contract services to weigh gas cylinders for facilities that have a high quantity of cylinders. O&M also includes cost to store records. The average annual estimated burden from implementation of the proposed revisions is $4,660 per facility in both the first and subsequent years, the estimated cost includes $3,100 in labor and $1,559 in O&M costs ($2021). The total labor costs for the proposed revisions for two subpart DD reporters are $6,200 for the initial and subsequent years. The total O&M costs for two reporters are $3,119 per year for record storage and for weighing of gas cylinders ($2021). See Appendix B, worksheet "Subpart DD (Applicability)" for additional information.
<IP_ADDRESS> Subpart HH

      For the purposes of estimating burden for the proposed subpart HH, the EPA estimated that 5 open landfills that have previously off ramped would resume reporting due to the changes to the GWP. Further, one open landfill would become a new reporter due to the changes to the GWP. The burden for these reporters was estimated by determining initial year and subsequent year labor hours from Appendix H of ICR No. 2300.18. EPA assumes that the 5 open landfills that previously off ramped have previously completed planning activities and have existing monitoring, recordkeeping, and reporting systems in place; therefore, annual costs for these facilities will mirror those of a subsequent year burden. The one new landfill reporter will incur initial year costs which include planning, QA/QC activities, sampling and analysis, recordkeeping, and reporting. Labor costs were also adjusted to account for burden from reporting new or revised data elements as estimated in the June 21, 2022 proposed rule, adjusted to $2021 (adds $5 per reporter). Labor costs are estimated at $7,625 per facility for the initial year and $4,767 per facility for subsequent years. Additionally, each subpart HH reporter will incur O&M costs of $62 per year per facility for record storage ($2021). The total labor costs for the proposed revisions for five previously off ramped reporters and one new reporter are $31,461 for the initial year and $28,603 for subsequent years. Additionally, the total O&M costs for the six reporters are $374 per year. See Appendix B, worksheet "Subpart HH (Applicability)" for additional information.
<IP_ADDRESS> Subpart II

      For proposed subpart II, the burden was estimated based on the assumption that two new facilities would be required to start reporting to the GHGRP. Estimated initial year activities for these reporters, based on Appendix H to ICR No. 2300.18, include time to become familiar with the rule requirements, planning, QA/QC activities, and time for measurements and calculations (e.g., amounts of biogas collected and recovered). Subpart II requires also flow meter calibrations once every three years, which are O&M costs. Labor costs are estimated at $2,644 per facility for the initial year and $2,356 per facility for subsequent years. Additionally, each subpart II reporter will incur O&M costs of $1,538 per year per facility for calibrations and record storage ($2021). The total labor costs for the proposed revisions for two new reporters are $5,288 for the initial year and $4,713 for subsequent years. Additionally, the total O&M costs for the two reporters are $3,077 per year. See Appendix B, worksheet "Subpart II  (Applicability)" for additional information.
<IP_ADDRESS> Subpart OO

      For subpart OO, the burden for proposed amendments to Table A-1 to subpart A was estimated based on the assumption that one new reporter would be required to start reporting to the GHGRP. The estimated burden for the new reporter is consistent for years one through three. Each year, the reporter would incur labor to plan, collect, calculate, and submit information via e-GGRT. Subpart OO requires importers develop an annual report that summarizes imports at the corporate level. Labor costs were also adjusted to account for burden from reporting new or revised data elements as estimated in the June 21, 2022 proposed rule, adjusted to $2021 (adds $13 per reporter). Labor costs are estimated at $5,592 for the one facility, based on the average labor hours from Appendix H to ICR No. 2300.18 and labor hours from revised data elements from the June 21, 2022 proposal, adjusted to $2021. Additionally, the one subpart OO reporter will incur O&M costs of $62 per year for record storage ($2021). See Appendix B, worksheet "Subpart OO (Applicability)" for additional information.
<IP_ADDRESS> Subpart TT

      For the purposes of estimating burden for the proposed subpart TT, the EPA estimated that one new reporter would be required to start reporting to the GHGRP. Estimated initial year costs for these reporters would include time to become familiar with the rule requirements, planning, QA/QC activities, time to complete measurements and calculations discussed in § 98.276, and time to submit information via e-GGRT. Labor costs are estimated based on the average labor hours from Appendix H to ICR No. 2300.18 and adjusted to $2021. Labor costs for the one subpart TT reporter include $4,853 for the initial year and $3,934 for subsequent years. Additionally, the subpart II reporter will incur operating and maintenance (O&M) costs of $62 per year for record storage ($2021). See Appendix B, worksheet "Subpart TT (Applicability)" for additional information.

 2.2 Addition of New Subparts
The EPA is proposing to add annual reporting requirements for greenhouse gases from the following sources categories in five new subparts to part 98 as follows:
Subpart B  -  Energy Consumption. The energy consumption source category applies to all direct emitting facilities that report to Part 98 purchase metered electricity or metered thermal energy products. Applicable thermal energy products include steam, hot water, chilled water, and other mediums used for heat transfer supplied under purchase contracts. Reporters subject to subparts UU and VV would not be required to report under subpart B.
Subpart WW  -  Coke Calciners. The proposed coke calcining source category consists of processes that heat petroleum coke to high temperatures in the absence of air or oxygen for the purpose of removing impurities or volatile substances in the petroleum coke feedstock. The proposed coke calcining source category includes, but is not limited to, rotary kilns or rotary hearth furnaces used to calcine petroleum coke and any afterburner or other equipment used to treat the process gas from the calciner. The proposed source category would include all coke calciners that exceed the 25,000 mtCO2e threshold in 40 CFR 98.2(a)(2).
Subpart XX  -  Calcium Carbide Production. Proposed subpart XX applies to any process unit that produces calcium carbide. Calcium carbide is an industrial chemical manufactured from lime (CaO) and carbon, usually petroleum coke. The production of calcium carbides results in emissions of CO2 and CH4. The proposed requirements would apply to all calcium carbide facilities.
Subpart YY  -  Caprolactam,  Glyoxal, and Glyoxylic Acid Production. Proposed subpart YY applies to any facility that produces caprolactam, glyoxal, or glyoxylic acid, excluding the production of glyoxal through the LaPorte process (i.e., the gas-phase catalytic oxidation of ethylene glycol with air in the presence of a silver or copper catalyst). The proposed requirements would apply to all caprolactam, glyoxal, or glyoxylic acid production facilities.
Subpart ZZ   -  Ceramics Production. Proposed subpart ZZ applies to facilities that meet the definition of a ceramics manufacturer. A facility would be considered a ceramics manufacturer if they annually consume at least 2,000 tons of carbonates or 20,000 tons of clay heated to a temperature sufficient to allow the calcination reaction to occur and operate a ceramics manufacturing process unit. The proposed requirements would apply to those facilities that exceed the 25,000 mtCO2e threshold in 40 CFR 98.2(a)(2).

2.2.1 Identifying Affected Reporters
<IP_ADDRESS> Subpart B  -  Energy Consumption

The number of affected reporters subject to proposed subpart B of Part 98 were determined based on the applicability of the proposed rule, which applies to direct emitting facilities that purchase metered electricity or metered thermal energy products and are required to report under 40 CFR 98.2(a)(1), (2), or (3). The requirements would not apply to suppliers or reporters in the following source categories: injection of carbon dioxide (subpart UU), or geologic sequestration of carbon dioxide with enhanced oil recovery using ISO 27916 (proposed subpart VV). The number of affected reporters was therefore estimated by reviewing the total number of direct emitters reporting for RY2021 (7,587 reporters), in addition to 200 entirely new reporters from subparts W, HH, II, OO, TT as discussed in section 2.1 of this document and 53 entirely new reporters from proposed subparts XX, YY, and ZZ, as discussed in this section 2.2.1 of this document. The burden was subsequently estimated by assuming a total of 7,840 reporters would submit reports under subpart B beginning in RY2025.
<IP_ADDRESS> Subpart WW  -  Coke Calciners

      The number of affected reporters subject to proposed subpart WW of Part 98 were determined based on a review of facilities currently reporting under Part 98 and conducting a search of additional facilities in the United States. The EPA identified an estimated 5 operating coke calcining companies in the US with 15 currently operating facilities based on available information from facilities subject to subpart Y of Part 98, facilities subject to the NSPS for Petroleum Refineries, and the Louisiana Department of Environmental Quality, Electronic Document Management System. See Technical Support Document For Coke Calcining: Proposed Rule For The Greenhouse Gas Reporting Program available in the docket for this rulemaking, Docket Id. No. EPA-HQ-OAR-2019-0424. Proposed subpart WW would apply to all coke calcining facilities with GHG emissions. Therefore, the impacts were estimated assuming all 15 facilities, including 3 facilities that previously reported under subpart Y of Part 98, would be required to report.
<IP_ADDRESS> Subpart XX  -  Calcium Carbide Production

      The number of affected reporters subject to proposed subpart XX of Part 98 was determined based on a review of facilities currently reporting under Part 98 and conducting a search of additional facilities in the United States. The only U.S. producer of calcium carbide, Carbide Industries LLC, currently reports under Part 98, subpart K  -  Ferroalloy Production (GHGRP Facility ID 528303). The facility voluntarily reports under subpart K as the subpart does not cover the production of calcium carbide. The EPA also identified a calcium carbide production plant located in Pryor, OK, that was owned by Carbide Industries but closed in March 2014. According to the company website (https://www.carbidellc.com), calcium carbide is the only product. See Technical Support Document For Calcium Carbide: Proposed Rule For The Greenhouse Gas Reporting Program available in the docket for this rulemaking, Docket Id. No. EPA-HQ-OAR-2019-0424. Because the proposed subpart would apply to all calcium carbide manufacturers, impacts were estimated for one potential facility.
<IP_ADDRESS> Subpart YY  -  Caprolactam,  Glyoxal, and Glyoxylic Acid Production

      The number of affected reporters subject to proposed subpart YY of Part 98 were determined based on a review of facilities currently reporting under Part 98 and conducting a search of additional facilities in the United States. The EPA identified approximately two caprolactam facilities, and likely two to four facilities that produce glyoxal and glyoxylic acid. The EPA identified two caprolactam production facilities that currently only report combustion emissions under subpart C: AdvanSix in Virginia and BASF in Texas. The EPA estimates potentially one glyoxal production facility. We identified a potential glyoxal production facility at a BASF unit in Geismar, Louisiana, shut down in 2014, which had previously reported to the GHGRP, as well as data reported under the Toxic Substances Control Act (TSCA) that identified four facilities in 2015 that claimed their glyoxal production status (i.e., as a domestic manufacturer or as an importer) and their quantities domestically manufactured and/or imported, were confidential business information (CBI). These four facilities also reported glyoxylic acid data under TSCA, although these facilities reported no domestically manufactured glyoxylic acid. We anticipate that at least two of these four facilities could be a glyoxal or glyoxylic acid manufacturer. See Technical Support Document For Caprolactam, Glyoxal, and Glyoxylic Acid Production: Proposed Rule For The Greenhouse Gas Reporting Program available in the docket for this rulemaking, Docket Id. No. EPA-HQ-OAR-2019-0424. Because the proposed subpart would apply to all caprolactam, glyoxal, and glyoxylic acid manufacturers, impacts were estimated for six potential facilities.
<IP_ADDRESS> Subpart ZZ  -  Ceramics Production

      The number of affected reporters subject to proposed subpart ZZ of Part 98 were determined based on a search of facilities in the United States and the proposed rule applicability. There are approximately 815 corporations (per the 2018 U.S. Census) representing an estimated 850 facilities in the ceramics manufacturing industry. The EPA is proposing that subpart ZZ would only apply to those facilities that meet the definition of a ceramics manufacturer, i.e., if they annually consume at least 2,000 tons of carbonates or 20,000 tons of clay heated to a temperature sufficient to allow the calcination reaction to occur, and operate a ceramics manufacturing process unit. The EPA conducted a threshold analysis for facilities that emit 10,000 mtCO2e, 25,000 mtCO2e, and 100,000 mtCO2e. Based on the threshold analysis, 34 ceramics manufacturing facilities would be required to report under proposed subpart ZZ. Therefore, impacts were estimated for 34 potential facilities. See Technical Support Document For Ceramics: Proposed Rule For The Greenhouse Gas Reporting Program available in the docket for this rulemaking, Docket Id. No. EPA-HQ-OAR-2019-0424.

2.2.2 Estimating Cost Impacts
To estimate costs for the five proposed new subparts, the EPA estimated labor hours for activities required to for reporting to the GHGRP including planning, QA/QC activities, sampling and analysis activities, recordkeeping, and reporting. Labor hours were estimated assuming a level of effort for activities currently conducted under similar requirements of part 98.
 Planning: Includes familiarizing with the rule and hours for setup of compliance activities including sampling and QA/QC.
 QA/QC: Includes calibration procedures and similar activities, as well as review of calculations, testing, or reports.
 Sampling and analysis: Includes completion of measurements or analyses and conducting the proposed calculations.
 Recordkeeping: Accounts for the time needed to document information, create paper copies, backup to the cloud, or utilize another recordkeeping method.
 Reporting: Includes labor for the time required to enter the proposed data elements into the EPA's electronic Greenhouse Gas Reporting Tool (e-GGRT).
To estimate labor costs for each subpart, the estimated labor hours for each activity were assigned to legal, managerial, technical, and administrative personnel and multiplied by labor costs using updated labor rates from the Bureau of Labor Statistics (May $2021). See Appendix A to this document for additional detail on the labor categories and labor rates referenced.
      Non-labor costs, including capital (equipment) and O&M costs, were also estimated for each subpart. Non-labor costs include capital and O&M costs such the cost to store records, such as a flash drive, paper file or cloud storage, as well as sampling and analysis costs (e.g., costs associated with collecting and analyzing samples to determine carbon content). The average non-labor costs that are incurred under each proposed subpart were estimated based on the costs associated with similar activities currently conducted under part 98, such as carbon content sampling costs. Non-labor costs were adjusted for inflation ($2021) using 2021 Chemical Engineering Plant Cost Index (CEPCI) annual values.
<IP_ADDRESS> Subpart B  -  Energy Consumption

      For the purposes of estimating burden for the proposed subpart B, the EPA estimated annual costs for planning for new reporters would include time to develop a Metered Energy Monitoring Plan (MEMP) in the initial year and time to update it annually. Annual QA/QC costs were estimated assuming time to confirm that electricity and energy meters comply initially with the specified standards for electric metering and periodically thereafter. The proposed subpart does not include any calculations, however, costs estimates were estimated for the time to estimate the fraction of electricity or metered thermal energy products attributable to each subpart. Recordkeeping costs were estimated assuming reporters review electric billing statements monthly. Labor costs are estimated at $1,119 per facility for the initial year and $600 per facility for subsequent years. Additionally, each subpart B reporter will incur operating and maintenance (O&M) costs of $62 per year per facility for record storage ($2021). Total labor costs for proposed new subpart B for 7,840 reporters are $8,771,243 in the first year and $4,700,877 in subsequent years, as well as $489,050 in O&M costs	. See Appendix B, worksheet "B (New Subpart)" for additional information.
<IP_ADDRESS> Subpart WW  -  Coke Calciners

      For the purposes of estimating burden for the proposed subpart WW, the EPA assumed 15 existing facilities would be required to start reporting under proposed subpart WW. The subpart WW facility burden is expected to be comparable to a facility reporting under subpart Q - Iron and Steel Production, as these subparts both rely on a carbon mass balance approach with carbon content sampling.
      The 15 affected facilities already report to the GHGRP under subpart Y - Petroleum Refineries and subpart C  -  General Stationary Fuel Combustion Sources, therefore EPA has assumed that the initial and subsequent year costs are the same. Each year, these reporters would incur labor and O&M costs. Specific labor costs include time to become familiar with changes to the rule requirements, QA/QC activities including review of reports, time to perform measurements and perform calculations, and time to record and enter information into e-GGRT. Labor costs are estimated at $2,523 per facility in the first year and $2,302 per facility in subsequent years. Additionally, each subpart WW reporter will incur O&M costs of $1,310 per year per facility for record storage and carbon content sampling and analysis ($2021).
      Only 1 of the 15 facilities currently reporting under subparts Y or C contains calciner units using CEMs. Reporting and recordkeeping costs for this facility would be expected to be similar to coke calciners using the mass based method, however, there is no anticipated burden for planning or QA/QC, and the facility would have a lower burden associated with sampling and calculations. The costs for a reporter using the CEMS option would result in a labor cost of $1,030 per facility ($2021) in initial and subsequent years.
      The total estimated labor costs for 15 facilities to report under proposed subpart WW is $37,847 in the first year and $34,525 in each subsequent year, and the total estimated operation and maintenance costs are $19,649 per year. See Appendix B, worksheet "WW (New Subpart)" for additional information.
<IP_ADDRESS> Subpart XX  -  Calcium Carbide Production

      To estimate the burden for proposed subpart XX, the EPA assumed one potential new facility that currently reports under part 98, subpart K. The one facility that would be subject to proposed subpart XX currently reports under part 98 subpart K (Ferroalloy Production) and subpart C (General Stationary Fuel Combustion). The estimated labor hours and costs for subpart XX include time to become familiar with the rule requirements and initial planning; for QA/QC activities including review of calculations, testing, and reports; to create paper records or utilize another recordkeeping method; and to complete measurements (carbon content) and perform calculations. The labor and O&M burden is expected to be comparable to a facility reporting under subpart K  -  Ferroalloy Production because of the similarity with the calculation, monitoring, recordkeeping and reporting requirements, however, under proposed subpart XX the reporter would analyze fewer process materials and would not be required to calculate CH4 emissions. Calculations include estimation of CO2 emissions from each calcium carbide process unit. Labor costs are estimated at $2,849 in the first year and $2,627 in subsequent years. Additionally, the subpart XX reporter will incur O&M costs of $62 per year for record storage ($2021). See Appendix B, worksheet "XX (New Subpart)" for additional information.
<IP_ADDRESS> Subpart YY  -  Caprolactam,  Glyoxal, and Glyoxylic Acid Production

      For the purposes of estimating burden for the proposed subpart YY, the EPA assumed six facilities would be required to start reporting to the GHGRP. The subpart YY facility burden is expected to be comparable to a facility reporting under subpart V - Nitric Acid Production for the Alternative Monitoring Method Option. These subparts both include emissions calculation methodologies for sources of nitrous oxide (N2O) based on emission factors and abatement technology destruction and removal efficiency (DRE). Annual costs would include time to become familiar with the rule requirements and initial planning and setup of compliance activities, QA/QC activities associated with maintaining equipment and review of measurements and calculations, and time to record information and submit information via e-GGRT. Annual burden also includes the labor costs for collection of measurements and analysis for estimation of N2O with emission factors and accounting for the DRE of any abatement technology. Labor costs are estimated at $2,048 per facility in the first year and $1,848 per facility in subsequent years ($2021). Additionally, each subpart YY reporter will incur O&M costs of $62 per year per facility for record storage ($2021).  The total estimated labor costs for 6 facilities to report under proposed subpart YY is $12,285 in the first year and $11,089 in each subsequent year, and the total estimated operation and maintenance costs are $374 per year. See Appendix B, worksheet "YY (New Subpart)" for additional information.
<IP_ADDRESS> Subpart ZZ  -  Ceramics Production

      To estimate the burden for the proposed subpart ZZ, the EPA assumed 34 ceramics manufacturing facilities would be required to report. The emissions from ceramics occur from the calcination of the materials. The labor and O&M burden is expected to be comparable to a facility reporting under the non-CEMS option for subpart S - Lime Manufacturing, which is also a calcination process. Sixteen of the 34 facilities currently report under subpart C of part 98; none of these facilities appear to use CEMS. Additionally, other air quality regulations for ceramics manufacturers do not require CEMS. Therefore, we assume most ceramics manufacturers would not have CEMs unless required by state or other regulations. Costs have therefore been	 estimated for the mass balance option. The annual costs for reporters under the proposed subpart ZZ would include labor and O&M costs and would be consistent for the initial year and subsequent years. Specific labor costs include time to become familiar with the rule requirements and setup of compliance activities, time to perform QA/QC activities including review of reports, time for measurements and calculations, and time to record and submit information via e-GGRT. Calculations include inputting the amounts of carbonate-based mineral into the equations to calculate CO2 emissions. We estimate that the recordkeeping and reporting burden from facilities using the CEMS option would be similar to costs for facilities using the mass balance method; however, these sources would not have burden associated with planning, QA/QC, or sampling and analysis. Labor costs are estimated at $2,267 per facility in the first year and $2,119 per facility in each subsequent year ($2021). Additionally, each subpart ZZ reporter will incur O&M costs of $62 per year per facility for record storage ($2021). The total estimated labor costs for 34 facilities to report under proposed subpart ZZ is $77,083 in the first year and $72,062 in subsequent years year, and the total estimated operation and maintenance costs are $2,121 per year. See Appendix B, worksheet "ZZ (New Subpart)" for additional information.

 2.3 	Revisions to Applicability for Certain Industry Sectors
The EPA is proposing amendments to certain subparts of part 98 that would revise the applicability for certain industry sectors, in order to improve the accuracy of the applicability estimation methodology, e.g., to account for changes in usage of certain GHGs or to update the emission factors used in the current emissions estimation equations.

2.3.1 Identifying Affected Reporters

Revisions to applicability to subpart P. The EPA is proposing amendments to subpart P (Hydrogen Production) which include expanding the source category to include non-merchant hydrogen production facilities. Specifically, EPA is proposing to amend the source category definition in section 98.160 to include all hydrogen production facilities which produce hydrogen gas as a product regardless of whether the product is sold. Through analysis and communications with facilities reporting to the GHGRP, the EPA has identified captive (non-merchant) hydrogen plants that are not currently required to report under subpart P or any other GHGRP subpart. Specifically, the EPA has identified one refinery facility that previously reported to subparts Y and P, but ceased reporting under both subparts after transitioning its refinery operations to a renewable fuels operation. Under the proposed rule, the one facility would be required to resume reporting for the hydrogen production. Additionally, the EPA anticipates one potential new reporter with captive hydrogen operations that could be subject to subpart P.
Revisions to applicability to subpart Y. The EPA is proposing amendments to subpart Y (Petroleum Refineries) which include revising the source category to remove coke calciners. Specifically, EPA is proposing to amend the source category definition in section 98.250 to remove coke calcining units as well as the associated monitoring, calculation, recordkeeping, and reporting requirements in sections 98.23, 98.254, 98.256, and 98.257. These sources would begin reporting under and meet the requirements of proposed subpart WW (see the estimated burden for proposed subpart WW in section 2.2.2 of this document).
Revisions to equations used to determine applicability of subpart HH.  Subpart HH (Municipal Solid Waste Landfills) applies to municipal solid waste landfills that generate methane in amounts equivalent to 25,000 metric tons CO2e or more per year, as determined according to subpart HH. Methane generation is estimated for comparison to the 25,000 mtCO2e threshold using Equation HH-5 (for landfills without gas collection systems) and Equation HH-7 (for landfills with gas collection systems) of subpart HH. The EPA is proposing amendments to subpart HH which would include accounting for methane emissions from large release events that are currently not quantified under the GHGRP, and is specifically proposing revisions to add a term to Equations HH-6, HH-7, and HH-8 to adjust the estimated methane based on surface monitoring measurements or based on lower default gas collection efficiencies. Because the proposed amendments would revise the methane generation estimate in Equation HH-7 to account for methane leak events, the EPA evaluated whether the proposed change would result in any new landfills previously below the 25,000 mtCO2e threshold becoming subject to Part 98.  The proposed amendments would largely impact those landfills with gas collection systems and controls that are already required to conduct surface monitoring under 40 CFR part 60, subpart WWW or XXX, 40 CFR part 60, subparts Cc or Cf, and 40 CFR part 62, subparts GGG and OOO. The proposed revisions to Equation HH-7 include a new term that takes the number of times a facility triggers a reading above the threshold (500 parts per million above background) set by the Part 60 and Part 62 standards and converts it to emissions. If a facility is not required to conduct the monitoring under the NSPS, EG, or FP, or elects not to conduct monitoring, they will report zero for the new term and use a lower default gas collection efficiency.
In 2016, the EPA's Office of Air Quality Planning and Standards (OAQPS) developed an inventory of landfills in the U.S. in order to conduct an economic impact analysis of 40 CFR part 60, XXX and 40 CFR part 60, subpart Cf. Based on various sources of information current through 2015, which included GHGRP data for RY2014 and 2015, EPA identified 1,142 landfills in the U.S. that met the date and design capacity criteria that would subject them to reporting uncontrolled nonmethane organic emission (NMOC) under the NSPS or EG, and, if these emissions exceed certain thresholds, install a GCCS and conduct surface emission monitoring. All but 99 of the identified landfills reported to the GHGRP.  Thus, the vast majority (~ 91%) of landfills subject to the NSPS or EG currently report to the GHGRP, and are presumed to already exceed the 25,000 mtCO2e threshold. For the 99 landfills that were not reporting the GHGRP, these landfills were identified as older, closed landfills that were likely not reporting to the GHGRP because their declining emissions are below 25,000 mtCO2e.  Because the majority of landfills identified in the OAQPS inventory are large enough to already be reporting to GHGRP, and the remaining facilities are closed landfills that are most likely to never report to the GHGRP, it is unlikely that the proposed revisions to Equation HH-7 would cause any existing facility not currently reporting to exceed the emissions reporting threshold, and there are no anticipated new reporters as a result of the proposed change.
2.3.2 Estimating Cost Impacts
<IP_ADDRESS> Subpart P

      For the purposes of estimating burden for the proposed changes to subpart P that impact applicability, the EPA assumed two facilities would be required to start reporting to the GHGRP. Because one affected facility previously reported under subparts Y and P, the initial year costs are assumed to only apply to one potential new reporter with captive hydrogen operations. Annual costs include time to become familiar with the rule requirements, QA/QC activities, time to annually determine the molecular weight and carbon content of the natural gas, and time to record and submit information via e-GGRT. Labor costs were also adjusted to account for burden from reporting new or revised data elements as estimated in the June 21, 2022 proposed rule, adjusted to $2021 ($16 per reporter). Labor costs are estimated at $1,916 per facility. Additionally, each affected subpart P reporter will incur O&M costs of $2,241 per year per facility for record storage and carbon content sampling and analysis ($2021). The total estimated labor costs for two facilities is $3,833 per year, and the total estimated operation and maintenance costs are $4,481 per year. See Appendix B, worksheet "Subpart P (Applicability)" for additional information.
<IP_ADDRESS> Subpart Y

      The burden for subpart Y is estimated by assuming three facilities with coke calciners currently reporting under subpart Y would no longer report under this subpart.  Instead, these 3 facilities would begin reporting under and meet the requirements of proposed subpart WW. The reporting costs for these facilities are reflected in the estimates for proposed subpart WW. There would be no change in costs for each of the remaining subpart Y reporters. The calculated savings were based on avoided labor costs (i.e., the cost of labor by facility staff to plan, keep records, gather and analyze performance tests, and submit information via e-GGRT) and the avoided monthly analysis to determine the carbon content of input materials. Labor costs savings are estimated at $2,302 per facility. Additionally, each affected subpart Y reporter will incur O&M costs savings of $1,310 per year per facility for record storage and carbon content sampling and analysis ($2021). The total estimated savings for two facilities is ($6,905) per year, and the total estimated operation and maintenance costs are ($3,930) per year. See Appendix B, worksheet "Subpart Y (Applicability)" for additional information.
<IP_ADDRESS> Subpart HH

      Because there are no anticipated new reporters as a result of the proposed amendments to Equation HH-7, there are no costs impacts anticipated with the determination of applicability of Subpart HH. However, additional labor burden due to the proposed revisions to Equations HH-6 through HH-8 was estimated for existing reporters and is discussed in section 2.4 of this document.

 2.4 Revisions to Monitoring and Calculation Methodologies
The EPA is proposing amendments to certain subparts of part 98 that would revise the burden associated with the data collection and monitoring requirements associated with certain calculation methodologies or modify the calculation methodology to improve the accuracy of emissions estimates.
2.4.1 Identifying Affected Reporters
Proposed revisions to calculation or monitoring requirements under Subpart AA. The EPA is proposing to amend subpart AA (Pulp and Paper Manufacturing) to add methodologies to calculate CH4, N2O and biogenic CO2 emissions from the combustion of biomass fuels other than spent liquor solids, as well as the combustion of biomass other than spent liquor solids with other fuels, according to the applicable methodology from the provisions for stationary combustion sources found at 40 CFR 98.33(a), 40 CFR 98.33(c), and 40 CFR 98.33(e). Based on a review of RY2010-RY2021 data, the EPA identified one reporter under subpart AA that combusts biomass (other than spent liquor solids) with other fuels that would be required to report annual biogenic CO2 emissions under subpart C (General Stationary Fuel Combustion).
Proposed revisions to calculation or monitoring requirements Subpart HH. The EPA is proposing to amend subpart HH (Municipal Solid Waste Landfills) to account for methane emissions from large release events that are currently not quantified under the GHGRP. Specifically, the EPA is proposing revisions to equations HH-7 and HH-8 to more clearly indicate that the fRec term is dependent on the gas collection system (GCS), proposing that the recovery system hours exclude periods when the GCS is malfunctioning, and proposing to clarify that the destruction device operating hours exclude periods when the destruction device is malfunctioning. Additionally, the EPA is proposing to add a term to Equations HH-6, HH-7, and HH-8 to adjust the estimated methane emissions based on methane surface monitoring measurements that are currently collected to comply with the control requirements in the landfill NSPS, EG, and Federal plan (40 CFR part 60, subpart WWW or XXX, 40 CFR part 60, subparts Cc or Cf, and 40 CFR part 62, subparts GGG and OOO). Facilities that are not subject to the landfill NSPS, EG, or Federal plan would either use proposed lower gas collection efficiency values or elect to monitor their landfill cover and use the higher gas collection efficiency values to adjust their reported methane emissions.
Based on recent (RY2020 through RY2023) data, there are on average 833 subpart HH reporters with gas collection systems reporting each year that would be required to adjust their emissions estimates using this currently collected data, in addition to 6 new reporters, for a total of 839 reporters (see section 2.1 of this document).
2.4.2 Estimating Cost Impacts
Proposed revisions to calculation or monitoring requirements Subpart AA. The change in burden for Subpart AA (Pulp and Paper Manufacturing) is estimated as the labor burden associated with required activities unique to the Tier 1 methodology, as identified in the most recent information collection request for the GHG reporting program (Appendix F to ICR No. 2300.18). The one affected reporter would have burden associated with the time to perform engineering calculations to total CO2, CH4, and N2O emissions as follows: time to perform engineering calculation to determine CO2 emissions (0.4 hours) using Eq C-1, C-1a, or C-1b of subpart C; and time to perform engineering calculation to determine CH4 and N2O emissions (0.9 hours) using Eq C-8, Eq C-8a, or Eq C-8b of subpart C using default high heat values and/or default emission factors. The total costs for the affected facility are $96 per year. There are no associated capital or O&M costs. See Appendix B, worksheet "Subpart AA (Calculations)" for additional information.
Proposed revisions to calculation or monitoring requirements under Subpart HH. The proposed amendments to subpart HH introduce revised calculation and monitoring methodologies to account for methane emissions from large release events. The proposed revisions to Equations HH-7 and HH-8 to more clearly indicate that the fRec term is dependent on the gas collection system (GCS), to clarify that the recovery system hours exclude periods when the GCS is malfunctioning, and to clarify that the destruction device operating hours exclude periods when the destruction device is malfunctioning are not anticipated to significantly impact burden. These revisions do not require facilities to conduct new monitoring or to collect data not already kept in facility operation and maintenance records. The proposed amendments to Equations HH-6, HH-7, and HH-8 to adjust the estimated methane emissions based on methane surface monitoring measurements are also not anticipated to significantly increase burden because these requirements would largely apply to facilities that already conduct monitoring to comply with the control requirements in the landfill NSPS, EG, and Federal plan (40 CFR part 60, subpart WWW or XXX, 40 CFR part 60, subparts Cc or Cf, and 40 CFR part 62, subparts GGG and OOO). These reporters are not anticipated to collect additional measurements for the purposes of the GHGRP, but would use their existing measurement data to adjust their engineering calculations. Facilities that are not subject to the landfill NSPS, EG, or Federal plan would use proposed lower gas collection efficiency values or elect to monitor their landfill cover to adjust their reported methane emissions. The affected reporters would have labor burden associated with the additional time required to perform engineering calculations (0.5 hours) based on the requirement to incorporate individual surface methane concentration measurements into Equations HH-6, HH-7, and HH-8 to adjust reported methane emissions. The total costs to 839 landfills to adjust their calculation methodology is $30,970 per year.  See Appendix B, worksheet "Subpart HH (Calculations)" for additional information.
 2.5 Revisions to Reporting and Recordkeeping Requirements
The EPA is proposing revisions that would add or revise data elements required to be reported in e-GGRT or for data elements that are retained as part of recordkeeping and entered by existing reporters into the EPA's Inputs Verification Tool (IVT). For certain subparts, the proposed revisions would add a new data element or revise an existing data element to improve or clarify the data reported. If finalized, the proposed revisions would apply beginning with RY2025.
2.5.1 Identifying Affected Reporters
The EPA is adding or revising 56 data elements in 12 existing subparts of Part 98. Table 2-2 below shows the number of reporters affected by the changes and the number of new, revised, and removed data elements in each subpart; the specific data elements that EPA is adding, revising, or removing in the proposed rule are included in Appendix A of this document. These revised reporting and data entry requirements apply to existing reporters in each affected subpart under Part 98.
The number of reporters affected under each subpart were identified based on the total number of reporters reporting to that subpart identified in RY2021 data. For certain data elements in subparts A, C, G, P, Y, AA, HH, OO, PP, and QQ, we identified a subset of the total reporters under each subpart who would be affected by the proposed changes, based on the data reported in RY2021. Additional details for each subpart may be found in Appendix B to this document. The number of reporters and costs associated with new reporting requirements under proposed new subparts B, WW, XX, YY, and ZZ are accounted for in section 2.2 of this document.
         Table 2-2. Number of Reporters and Data Elements Impacted by
                                    Subpart
                   # Reporters Affected by Proposed Changes
                            # of New Data Elements
                          # of Revised Data Elements
                            # Removed Data Elements
A- General Provisions
                                     7,840
                                       2
                                       0
                                       0
C  -  General Stationary Fuel Combustion Sources
                                      346
                                       7
                                       0
                                       0
F  -  Aluminum Production
                                       7
                                       2
                                       0
                                       0
G  -  Ammonia Manufacturing
                                      29
                                       1
                                       0
                                       0
N  -  Glass Production
                                      100
                                       2
                                       1
                                       0
P  -  Hydrogen Production
                                      116
                                       7
                                       2
                                       0
Y  -  Petroleum Refineries
                                       6
                                       1
                                       0
                                      8*
AA  -  Pulp and Paper Manufacturing
                                       1
                                       2
                                       0
                                       0
HH  -  Municipal Solid Waste Landfills
                                     1,126
                                      17
                                       3
                                       0
OO  -  Suppliers of Industrial Greenhouse Gases
                                      104
                                       3
                                       0
                                       0
PP  -  Suppliers of Carbon Dioxide
                                      11
                                       0
                                       3
                                       0
QQ - Importers and Exporters of Fluorinated Greenhouse Gases Contained in Pre-Charged Equipment or Closed-Cell Foams
                                      33
                                       3
                                       0
                                       0
       	*The proposed amendments to subpart Y would remove 8 data elements associated with coke calcining, due to proposed changes to applicability of subpart Y. Reporters would be required to report similar data elements under proposed subpart WW. The burden reduction associated with changes to applicability to subparts Y and WW is accounted for in sections 2.2 and 2.3 of this document.

2.5.2 Estimating Cost Impacts
All costs to the regulated industry resulting from the changes to new, revised, or removed data elements for existing subparts are labor costs (i.e., the cost of labor by facility staff to submit recorded information via e-GGRT or to enter values into IVT). There are no capital or operation and maintenance or training costs associated with the proposed revisions to add, revise, or remove data elements, because the proposed data elements may generally be obtained from existing company records or are readily available from existing information gathered under part 98; therefore, no additional monitoring or sampling is required. Similarly, as the new data elements would be added to existing e-GGRT data entry screens, facilities would not require additional training on EPA data systems.  For the limited cases where the proposed revisions would require monitoring for the collection of additional data, the change in burden is estimated in section 2.4 of this document. Capital and operation and maintenance costs associated with additional rule revisions, including revisions to applicability or changes to monitoring, are estimated in sections 2.1 through 2.4 of this document and Appendix A.
The change in burden was calculated for each subpart by determining the annual labor hours required to review the new, revised, or removed data elements and applying labor costs. Updated labor rates from the Bureau of Labor Statistics were applied (May $2021). The change in technical labor hours associated with revisions that add, revise, or remove data elements was calculated by multiplying the number of data elements that were added, substantially revised (such that different data are required to reported or entered into IVT), or removed in each subpart (i.e., number of data elements added plus the number of data elements revised, minus the number of data elements removed) by the number of hours required to review and report each data element. EPA assumed 3 minutes of technical labor to calculate each data element using readily available data and to submit the value via e-GGRT or enter the value into IVT. For all data elements, managerial and clerical labor hours were then estimated as 5% and 10% of the total technical hours required, respectively. Annual hourly estimates were determined based on the number of reporters that are anticipated to be required to report each new and revised data element or cease reporting each removed data element. For each subpart the incremental change in the hourly labor was multiplied by the number of respondents identified for each subpart, as determined in section 2.5.1 of this document.
For all facilities impacted by new or revised data elements that are reported or entered into IVT (subparts A, C, F, G, N, P, Y, AA, HH, OO, PP, and QQ), the total annual cost is $148,185. The average burden increase is approximately $16 per facility. Table 2-3 of this document reflects the total and annual average costs by subpart for the new, revised, or removed data elements.
All changes in burden will be realized in the RY2025 annual reporting for existing reporters in subparts A, C, F, G, N, P, Y, AA, HH, OO, PP, and QQ. See Appendix B, worksheet "Reporting Cost Summary" for additional information.
 Table 2-3. Average Annual Costs for Revisions to Reporting and Recordkeeping
Subpart
                   # Reporters Affected by Proposed Changes
                         Annual Cost by Sector ($2021)
Annual Avg. Cost Per Affected Reporter ($2021)
A
                                     7,840
                                    $64,133
                                      $8
C
                                      346
                                    $9,906
                                      $29
F
                                       7
                                      $57
                                      $8
G
                                      29
                                     $119
                                      $4
N
                                      100
                                    $1,227
                                      $12
P
                                      116
                                    $3,346
                                      $29
Y
                                       6
                                      $25
                                      $4
AA
                                       1
                                      $8
                                      $8
HH
                                     1,126
                                    $67,757
                                      $60
OO
                                      104
                                    $1,088
                                      $10
PP
                                      11
                                     $135
                                      $12
QQ
                                      33
                                     $384
                                      $12
Total

                                   $148,185
                                      $16

 2.6 Technical Corrections and Clarifications with No Quantifiable Impact
In addition to the amendments discussed in sections 2.1 through 2.5, EPA is proposing revisions and clarifications to several subparts in the GHG reporting rule that are not anticipated to have a significant impact on burden. This includes revisions that are intended to clarify rule requirements that have been the subject of uncertainty for reporters and resulted in burden associated with research or review of rule requirements, or correction of reported data, minor editorial corrections such as corrections to equation terms or cross-references, and harmonizing requirements. In many cases, these proposed revisions were determined to have no impact or a minimal reduction in burden that is not quantifiable. For example, some proposed amendments would reduce the burden associated with repeated verification and correction of errors submitted in reports. Although we anticipate that the proposed revisions would reduce the time and burden associated with reporting, it is unfeasible to anticipate the number of reporters who would realize an actual burden reduction. These amendments are discussed further in Appendix A of this document. EPA is also proposing confidentiality determinations for new or substantially revised reporting data elements which do not affect the burden on reporters, as presented in Appendix A.

Summary of Burden Impacts
The proposed Supplemental Notice of Revisions and Confidentiality Determinations for Data Elements Under the Greenhouse Gas Reporting Rule is anticipated to result in a minimal increase in program burden. We anticipate an increase in burden for revisions that would improve data quality where the EPA is proposing to collect data on new emissions or from new emission sources or proposing to add or revise the data entered or reported in e-GGRT.
The average annual incremental labor costs from implementation of the proposed revisions are estimated at $11,748,619 in the first year and $7,664,140 in subsequent years ($2021), with $3,225,282 in operation and maintenance (O&M) costs. The incremental implementation costs by subpart are summarized in Table 3-1 below. One-time implementation costs are incorporated into first year costs, while subsequent year costs represent the total incremental annual burden that will be incurred by the impacted reporters. Section 3.0 and Appendix A to this document provide a more detailed discussion of these impacts for each affected subpart.
        Table 3-1. Incremental Implementation Costs by Subpart ($2021)

                                    Subpart
                                  Labor Costs
                              Capital and O&M

                                 Initial Year
                               Subsequent Years

A  -   General Provisions
                                                                       $64,133
                                                                       $64,133
                                                                          $-
B  -  Energy Consumption
                                                                    $8,771,243
                                                                    $4,700,877
                                                                      $489,050
C  -   General Stationary Fuel Combustion Sources
                                                                        $9,906
                                                                        $9,906

F  -  Aluminum Production
                                                                           $57
                                                                           $57

G  -  Ammonia Manufacturing
                                                                          $119
                                                                          $119

I  -  Electronics Manufacturing
                                                                          $-
                                                                          $-
                                                                          $-
N  -  Glass Production
                                                                        $1,227
                                                                        $1,227

P  -  Hydrogen Production
                                                                        $7,179
                                                                         $7,179
                                                                        $4,481
V  -   Nitric Acid Production
                                                                       $(2,680)
                                                                       $(2,680)
                                                                      $(11,085)
W  -  Petroleum and Natural Gas Systems
                                                       $             2,620,418
                                                   $                 2,620,418
                                                        $            2,717,864

Y  -  Petroleum Refineries
                                                                       $(6,881)
                                                                       $(6,881)
                                                                       $(3,930)
AA  -  Pulp and Paper Manufacturing
                                                                          $104
                                                                          $104

DD  -  Electrical Transmission
                                                                        $6,200
                                                                        $6,200
                                                                        $3,119
HH  -  Municipal Solid Waste Landfills
                                                                      $130,188
                                                                      $127,330
                                                                          $374
II - Industrial Wastewater Treatment
                                                                        $5,288
                                                                        $4,713
                                                                        $3,077
OO  -  Suppliers of Industrial Greenhouse Gases
                                                                        $6,680
                                                                        $6,680
                                                                           $62
PP  -  Suppliers of Carbon Dioxide
                                                                           $135
                                                                           $135
                                                                             $-
QQ  -   Importers and Exporters of Fluorinated Greenhouse Gases Contained in Pre-Charged Equipment or Closed-Cell Foams
                                                                          $384
                                                                          $384

RR  -  Geologic Sequestration of Carbon Dioxide
                                                                          $-
                                                                          $-
                                                                          $-
TT  -   Industrial Waste Landfills
                                                                        $4,853
                                                                        $3,934
                                                                           $62
WW  -   Coke Calciners
                                                                       $37,847
                                                                       $34,525
                                                                       $19,649
UU  -  Injection of Carbon Dioxide
                                                                          $-
                                                                          $-
                                                                          $-
VV  -   Geologic Sequestration of Carbon Dioxide with Enhanced Oil Recovery Using ISO 27916
                                                                          $-
                                                                          $-
                                                                          $-
XX  -   Calcium Carbide Production
                                                                        $2,849
                                                                        $2,627
                                                                           $62
YY  -   Caprolactam,  Glyoxal, and Glyoxylic Acid Production
                                                                       $12,285
                                                                       $11,089
                                                                          $374
ZZ  -  Ceramics Production
                                                                       $77,083
                                                                       $72,062
                                                                        $2,121
Total
                                                                   $11,748,619
                                                                    $7,664,140
                                  $3,225,282

The annual undiscounted labor, O&M, and total implementation costs for all subparts combined, along with the net present value (PV) and the equivalent annual value (EAV) discounted at 3% and 7% for the period from 2025 to 2030 are summarized in Table 3-2 below.

Table 3-2. Summary of Annual Undiscounted Costs and PV/EAV Discounted at 3% and 7%.
                                     Year
                                  Labor Costs

                                 O&M Costs

                                  Total Costs

                                     2025
                                 $11,748,619
                                  $3,225,282
                                 $14,973,901
                                     2026
                                  $7,664,140
                                  $3,225,282
                                 $10,869,422
                                     2027
                                  $7,664,140
                                  $3,225,282
                                 $10,869,422
                                     2028
                                  $7,664,140
                                  $3,225,282
                                 $10,869,422
                                     2029
                                  $7,664,140
                                  $3,225,282
                                 $10,869,422
                                     2030
                                  $7,664,140
                                  $3,225,282
                                 $10,869,422
Discount Rate
                                      3%
                                      7%
                                      3%
                                      7%
                                      3%
                                      7%
PV
                                                                   $44,158,861
                                                                   $37,709,062
                                                                   $16,963,077
                                                                   $14,367,695
                                                                   $61,121,938
                                                                   $52,076,758
EAV
                                                                    $9,642,289
                                                                    $9,196,889
                                                                    $3,703,965
                                                                    $3,504,147
                                                                   $13,346,254
                                                                   $12,701,037

Small Entity Impacts
 4.1 Background for Small Entity Impacts
The EPA evaluated the impacts of the proposed revisions where it identified small entities could potentially be affected and considered whether additional measures to minimize impacts were needed. In evaluating the impacts of the proposed revisions, the EPA assessed the costs and impacts to small entities in three areas, including: (1) amendments that revise the number or types of facilities required to report (i.e., updates of the GHGRP's applicability to certain sources), (2) changes to refine existing monitoring or calculation methodologies, and (3) revisions to reporting and recordkeeping requirements for data provided to the program. The primary costs associated with the rule are associated with revisions that change how part 98 applies to certain sources or that change the number of facilities reporting under certain subparts of part 98. These costs include initial labor and non-labor costs for reporters who have not previously been subject to part 98 to come into compliance with the rule, as well as subsequent year costs for continued compliance with the rule. These include:
          Reporters who would be affected by the proposed revisions to Table A - 1 to part 98, where a change to GWPs would affect reporters that are currently at or close to the 25,000 mtCO2e reporting threshold, or that would affect a reporter's ability to offramp from part 98 reporting as determined under 40 CFR 98.2(i). These revisions are anticipated to result in an increase in the number of reporters under subparts W, DD, HH, II, OO, and TT.  (Described in section 2.1 of this document).
          Revisions to include or exclude certain types of facilities under subparts P (Hydrogen Production) and Y (Petroleum Refineries). (Described in section 2.3 of this document.)
          The proposed addition of new source categories for energy consumption; coke calcining; calcium carbide; caprolactam, glyoxal, and glyoxylic acid production; and ceramics manufacturing under proposed subparts B, WW, XX, YY, and ZZ. (Described in section 2.2 of this document.)

The EPA also considered other costs, including additional labor costs where the proposed rule would add or revise monitoring and calculation methods that would require additional data to be collected or estimated (subparts AA and HH) (section 2.4 of this document), and where reporters would be required to submit additional data that we anticipate could be obtained from existing company records or are readily available or estimated from other data currently gathered under part 98 (subparts C, F, G, N, P, Y, AA, HH, OO, PP, and QQ) (section 2.5 of this document).

 4.2 Methodology
To evaluate whether this proposed rule would have a substantial impact on a significant number of small entities, the EPA evaluated the costs of the proposed amendments on potential new and existing entities. The EPA first identified the types of entities that were most likely to be impacted by the primary (and most substantive) costs associated with the rule, i.e., those facilities affected by revisions that change how part 98 applies to certain sources or that change the number of facilities reporting under certain subparts of part 98. We then sought out information on the affected facilities to identify what portion of these facilities could be small entities, using two different scenarios.
Scenario 1 (Individual Facility Approach). In some cases, the proposed revisions would only impact a handful of reporters from a specific industry or sector, and the EPA was able to specifically identify those specific entities from existing reporters or from other resources. For proposed revisions that were anticipated to apply to a small number of reporters or where the EPA identified specific affected facilities, the EPA employed the individual facility approach. This included proposed revisions where the EPA identified specific facilities that have not previously been required to report to part 98 may potentially be required to come into compliance with the rule. The individual facility approach was applied for facilities who would be subject to reporting under proposed subparts P, WW, XX, YY, and ZZ. For the individual facility approach, we evaluated facility-specific data to identify each parent company, primary NAICS classification, the number of employees, and financial data (sales receipts) to assess whether the entity met the Small Business Administration size standards for the industry category. For each entity, we then subsequently estimated a cost-to-sales ratio (CRR) based on the total annualized reporting costs (including costs for proposed revisions to subparts A, B, and the individual subpart) to the reported annual sales receipts for each establishment. Where revisions for a source category are proposed in both the 2022 Data Quality Improvements Proposal and in this supplemental notice, the costs per facility in this supplemental proposal were adjusted to account for revisions from the 2022 Data Quality Improvements Proposal. Results of this review are described in section 4.3.1 of this document.

Scenario 2 (Survey Sample Approach). In other cases, the proposed revisions are estimated to impact a larger number of entities across multiple sectors or from a specific sector. For proposed revisions that would apply to a large number of reporters or across multiple sectors, analyzing individual entity business data would be resource intensive. In order to analyze the small entity impacts for these reporters, the EPA employed a survey sample approach. The survey sample approach consists of review of available reported or solicited data from a sample of facilities that are representative of the total population of affected facilities, in order to estimate the likelihood of impacts on small entities in the total population. Because the revisions proposed to subparts B (as applied to all direct emitting facilities and described in section 2.2 of this document) and W (as applied to new reporters potentially affected by the proposed revisions to Table A - 1 to subpart A of part 98 and described in section 2.1 of this document) were anticipated to potentially affect a larger number of entities, the survey sample approach was applied in order to estimate the small entity impacts for the total population of affected reporters. The survey sample approach is based on a survey of a sample of the total population of GHGRP reporters to approximate the size distribution of companies reporting under various subparts and NAICS codes. The survey estimates the business size distribution of reporters in the sample and the annual sales receipts for each parent company, which are compared to the estimated compliance costs.
For the survey sample approach, the EPA reviewed RY2021 data and randomly surveyed 565 reporters in order to develop a sample size representative of the population of GHGRP reporters and reflective of the distribution of companies reporting under individual subparts, NAICS codes, and entity sizes.  The survey sample approach included the following steps, which are detailed below:
 Establishing the sample size required to achieve precise estimates of the number of small entities.
 Selecting the initial sample.
 Soliciting business information from facilities for the final sample survey.
 Calculating weights for the final sample.
 Analyzing the survey data using statistical software.
The survey sample results provide sample and weight frequencies of small businesses, estimated mean cost-to-sales ratios, and estimated number of facilities exceeding a one percent cost-to-sales ratio in the total current population for selected business sizes. These estimated proportions and means were applied to the expected population of affected facilities. Results of this review are described in section 4.3.2 of this document.
Establishing the sample size. To establish the required sample size to measure the number of small entities (which may include small businesses or small governments), the Agency reviewed all reporters to the GHGRP in RY2021. A total of 8,105 total reporters were initially identified based on a compiled dataset including emissions data from FLIGHT, EnviroFacts, and GHGRP. In order to select a sample of reporters who would be subject to subpart B or new reporters subject to subpart W under the proposed rule, we excluded reporters who only reported to the supplier or CO2 injection subparts LL, MM, NN, OO, PP, QQ, UU, and VV (515 facilities), as well as three reporters with no listed subpart and no annual report. From the remaining 7,587 facilities (which included 5 facilities that only report to subpart RR), the EPA identified 2,307 facilities reporting to subpart W. We assumed all 7,587 direct emitter facilities would potentially be required to report under subpart B. The Agency estimated that a sample of between 550 and 600 (depending on the proportion for which business size information can be determined) would yield a margin of error of +-9 percent or less for estimates of the proportion of reporters that are a small business. Because the sample was drawn randomly from the relevant population of current facilities, and data was gathered from reliable records, the sample is representative and has very low risk of bias.
      Selecting the initial sample. In order to evaluate small business status for both reporters subject to subpart B and reporters subject to subpart W, the Agency solicited business information from a random sample of 565 facilities. These facilities were selected randomly  using stratified sampling, with two strata defined as (a) facilities reporting under subpart W and (b) facilities not reporting under subpart W.  The 565 facilities in the solicited sample were drawn from the population of 7,587 current facilities, which excludes those that reported only to subparts LL, MM, NN, OO, PP, QQ, UU, or VV. The sample size of 565 was allocated proportionally between the two strata, randomly sampling these two strata of reporters without replacement until the sample included 180 facilities that report to subpart W, and 385 facilities that do not report to W.
      Soliciting business information from facilities for the final sample. Next, the Agency evaluated each facility at the parent entity level to determine whether the reporters were part of a small entity and whether the annualized costs of the amendments would have a significant impact on a substantial number of small entities. For each facility in the sample, the Agency collected facility name, facility address, and the name of the parent company from the GHGRP RY2021 data. Business and financial data, including the number of employees, sales receipts, and primary NAICS codes at the parent company level for each facility in the survey, was then collected to assess the entity size and whether the entity met the Small Business Administration size standards for the industry category. For each entity, the Agency used the North American Industry Classification System (NAICS) codes associated with each facility to determine the SBA size definition of a small entity within that industry. Then, the number of employees or the revenue (according to the SBA definition) was used to determine whether the entity was considered a small entity.
      DemographicsNow was used to find information on the parent companies, including the number of employees and sales receipts at the parent company level for each facility in the sample. Of the solicited sample, information was available on DemographicsNow for 173 of the 180 facilities reporting to subpart W and for 346 of the 385 facilities not reporting to subpart W. Of the 565 solicited facilities, the 519 with available information were treated as "respondents," yielding a very low nonresponse rate of 8.1 percent. The entity size for subpart B (presented below) was evaluated based on the total number of facilities in the sample (519). The entity size for subpart W is evaluated based on the total number of facilities in the sample reporting to subpart W (173).
      Calculating weights for the final sample. Each facility in the final (responding) sample represents some number of facilities in the broader population. Weights allow for the calculation of statistical metrics for the full population while scaling appropriately from the sample. In general, weights are calculated from the selection probabilities used to draw the sample. The weights for subpart B and subpart W reporters for the final respondent sample were calculated according to the methodology in Appendix C of this document.
      Table 4-1, below, shows the population counts, the solicited sample size, and the responding sample size for which small business status could be determined.
Table 4-1. Survey Design Information

                             Stratum 1:
Subpart W
                           Stratum 2:
Not Subpart W
                               Total:
Subpart B
Current Total Population of Facilities
                                     2,307
                                     5,280
                                     7,587
Solicited Sample Size
                                      180
                                      385
                                      565
Responding Sample Size
                                      173
                                      346
                                      519
Final Survey Weight
                                     13.3
                                     15.3
                                      NA
Expected Number of Affected Facilities
                                      188
                                      NA
                                     7,840
Notes:
[a] The current total population of facilities in subpart B excludes facilities reporting only to subparts LL, MM, NN, OO, PP, QQ, UU, or VV.
[b] All sampled facilities belong to subpart B, which was partitioned into two strata based on membership in subpart W.
[c] For subpart B, the expected number of facilities is equal to the estimate of the total number of direct emitters reporting to subpart B following the proposed rule, including existing and new reporters.
[d] For subpart W, the expected number of facilities is equal to the number of new facilities expected to be affected by the proposed rule.
[e] Survey weights were assigned based on strata (subpart W or not subpart W). As such, weights do not apply to subpart B.

	Analyzing the survey data using statistical software. Finally, the survey data were analyzed using SAS/STAT software (SAS 9.4) to provide sample and weighted frequencies for small businesses. The CRRs from the sample are used with the weighted frequencies to estimate mean CRRs and the number of facilities exceeding a one percent cost-to-sales ratio to the total population for business sizes of 1-99 employees, 100-499 employees, and 500+ employees, with a 95 percent confidence interval (CI). The mean CRR and associated CI provides an estimate of the range of cost-to-sales ratios expected to apply to affected facilities in a given business size that would be expected in the total population. Specifically, when generalizing from the sample to the full population, the Agency is 95 percent confident that the population's true mean CRR lies in the CI. The number of facilities exceeding a one percent cost-to-sales ratio provides an estimate of the number of entities in a given business size range that would be expected to have a significant impact (i.e., the proposed rule costs are estimated to exceed greater than 1 percent of a facility's total sales receipts) in the total population.
      For each entity in the survey sample, we estimated the CRR based on the total annualized reporting costs (including costs for proposed revisions to subparts A, B, and the individual subpart) to the reported annual sales receipts for each establishment (adjusted to account for revisions from the 2022 Data Quality Improvements Proposal). The Agency calculated a CRR for each facility in the sample using its expected annual cost and the annual sales receipts of its parent entity (as reported in DemographicsNow). When determining the mean CRR associated with subpart B, the expected costs under subparts A and B were summed since all facilities reporting to subpart B would also report new data elements under subpart A. Similarly, for subpart W, the expected costs under subparts A, B, and W were summed for purposes of calculating facilities' cost-to-sales ratios.
      SAS/STAT was subsequently used to calculate the following quantities and their 95 percent confidence intervals for each stratum:
 The proportion of facilities owned by a small business parent company,
 The mean CRR in the first year of the rule,
 The mean CRR in subsequent years of the rule,
 The proportion of facilities with a first-year CRR exceeding 1 percent, and
 The proportion of facilities with a subsequent-year CRR exceeding 1 percent.

      These quantities were estimated for the current populations of facilities reporting to subpart B, subpart W, and subpart HH. In the case of subparts W and HH, affected entities only include new reporters that will be impacted by the proposed rule. For subpart B, all current and future reporters that would be subject to subpart B will be affected by the proposed rule.  Accordingly, the Agency applied the survey estimates of the proportions and CRRs to the expected number of affected facilities. Extrapolating from the sample in this manner involves a reasonable assumption that the population of current facilities is representative of facilities affected by the proposed rule. Results of this review are described in section 4.3.2 of this document.
      Other affected entities (not included in Scenario 1 or 2). The EPA's review of small business impacts assessed the types of entities that were most likely to be impacted by the primary costs associated with the rule (i.e., those facilities affected by revisions that change how part 98 applies to certain sources or that change the number of facilities reporting under certain subparts of part 98). For a small subset of potential reporters affected by proposed revisions to Table A-1 in subparts DD, II, OO, and TT, the EPA did not identify specific affected entities and did not identify a sufficient number of reporters in its survey sample to apply the individual facility approach or survey sample approach described in Scenario 1 or 2. However, the EPA reviewed available costs and data for similar facilities identified in the affected industry sectors to consider whether the rule costs were likely to have a significant regulatory burden on a substantial number of small entities in each sector.
      The EPA also reviewed the costs to existing reporters under other subparts affected by other proposed revisions with secondary (less substantial) costs, such as where the Agency proposed revisions to calculation and monitoring requirements, or proposed to require reporting of new data elements in a facility's existing annual report. Results of this review are described in section 4.3.3 of this document.
 4.3 Results of Small Entity Impacts Analysis

4.3.1 Results from Scenario 1 (Individual Facility Approach)

      The individual facility approach was applied for facilities who would be subject to reporting under proposed subparts P, WW, XX, YY, and ZZ. Specific facility business data (including number of employees and sales receipts) was located for 35 of the estimated 53 new facilities reporting under subparts P (one facility), WW (13 facilities), XX (one facility), YY (two facilities), and ZZ (18 facilities). The EPA evaluated whether each of the 35 facilities was a small business and estimated the cost-to-sales ratio for each facility. Based on the review, the cost-to-sales ratio was found to be less than one percent for all entities regardless of business size. Therefore, it is anticipated that the costs of the proposed rule would not have a significant regulatory burden for these entities. Although the EPA was unable to identify with certainty all potential reporters estimated to newly report under subparts P (estimated to apply to two potential hydrogen production facilities), WW (estimated to apply to 15 coke calcining facilities), YY (estimated to apply to six potential facilities) and ZZ (estimated to apply to 34 potential ceramics manufacturing facilities), it is anticipated that the identified facilities reviewed are representative for each respective industry and that no small entities would be subject to the proposed regulations. Additionally, for subparts P and WW, it is anticipated that these are predominantly large emission sources that have historically exceeded the 25,000 mtCO2e threshold and have previously reported under part 98 (e.g., under subpart Y). For subpart ZZ (Ceramics Manufacturing), EPA is proposing to define the source category to apply to facilities that annually consume at least 2,000 tons of carbonates or 20,000 tons of clay. The proposed source category definition establishes a minimum production level as a means to exclude small artisan-level ceramics manufacturing processes, to further reduce the potential burden for small entities. For these reasons, the proposed revisions to subparts P, WW, XX, YY, and ZZ would have no significant regulatory burden for any directly regulated small entities.

4.3.2 Results from Scenario 2 (Survey Sample Approach)

The proposed revisions to require reporting of energy consumption data under subpart B would apply to approximately 7,840 reporters, including 7,587 facilities reporting under direct emitter subparts and 253 new reporters. First, the EPA considered the mean cost-to-sales ratio for entities with parent companies in the size ranges of 1-99 employees, 100-499 employees, and 500+ employees. As detailed further below, for facilities reporting to subpart B, the mean cost-to-sales ratio for the 1-99 employee size range is 0.1% (CI 0.0  -  0.1%) for the first year and 0.0% (CI 0.0  -  0.1%) in subsequent years. The mean cost-to-sales ratio for the 100-499 employees and 500+ employees size ranges fell below 0.05%. Therefore, it is estimated that facilities who are required to newly report under subpart B in all size ranges are likely to have a cost-to-sales ratio of less than 1%. We further determined what portion of the total population of reporters anticipated to be subject to subpart B (7,840 facilities) might be small businesses where the cost to sales ratio could exceed 1%. The number of entities reporting under subpart B estimated to exceed a cost-to-sales ratio of one percent is estimated at 15.8 (CI 0  -  45.7) in the first year (rounded to 16 reporters, or 0.20% of total reporters) and 0 in subsequent years for entities in the 1-99 employee size range. There were no entities in the 100-499 employees or 500+ employees size ranges estimated to have a cost-to-sales ratio of greater than one percent, and we expect no significant impacts from the proposed revisions to subpart B for these business sizes.
However, the proposed requirements for subpart B were developed to minimize impacts to small entities. The proposed rule does not include emissions calculations. The proposed requirements are limited to development of a metered energy monitoring plan and recordkeeping and reporting activities that may be completed using information that we anticipate is readily available to facilities that already report under part 98, predominantly in their energy bills. The EPA further anticipates that small entities are likely to have smaller operations with fewer energy meters and therefore it would be less burdensome to develop a monitoring plan for these sources. For these reasons, the proposed revisions to subpart B would not have a significant regulatory burden on a substantial number of small entities.
The number of small entities potentially affected by the proposed revisions to Table A - 1 to part 98 under subpart W were also estimated. The proposed revisions would apply to approximately 188 new reporters. First, we considered the mean cost-to-sales ratio for entities in the size ranges of 1-99 employees, 100-499 employees, and 500+ employees. For subpart W, the estimated mean cost-to-sales ratio for the 1-99 employee size range is 0.5% (CI 0.3  -  0.7%) for the first year and 0.5% (CI 0.3  -  0.7%) in subsequent years. The mean cost-to-sales ratio for the 100-499 employees and 500+ employees size ranges fell below 0.05%. Therefore, we estimate that facilities who are required to newly report under subpart W in all size ranges are most likely to have a cost-to-sales ratio of less than 1%. Next, we determined what portion of the total population of new reporters anticipated to be subject to subpart W (188 facilities) might be small businesses where the cost to sales ratio could exceed 1%. The number of new subpart W entities exceeding a cost-to-sales ratio of one percent is estimated at 7.6 (CI 2.3  -  12.9) in the first year and in subsequent years (rounded to 8 reporters, or 4.0% of total new reporters) for entities in the 1-99 employee size range. There were no entities for subpart W in the 100-499 employees or 500+ employees size ranges estimated to have a cost-to-sales ratio of greater than one percent and we expect no significant impacts from the proposed revisions to Table A - 1 for subpart W sources in these business sizes. For these reasons, the proposed revisions to Table A - 1 would not have a significant regulatory burden on a substantial number of small entities under subpart W.
We note that the estimated costs to facilities subject to subpart W reflect the burden for facilities to comply with the existing requirements of the GHGRP and were adjusted to include costs from the 2022 Data Quality Improvements Proposal. The EPA anticipates issuing a separate proposed rulemaking to implement certain provisions of the Methane Emissions and Waste Reduction Incentive Program that would propose further revisions to the requirements of Subpart W and which could also impact compliance costs. There are no additional changes to subpart W included in the proposed rulemaking that would impact burden.