MEMORANDUM

TO:	Jessica Gordon, Rachel Schmeltz, EPA

FROM:	Donna Lazzari, Jason Renzaglia, Tracy Curtis, ERG

DATE:	September 30, 2013

SUBJECT: 	Assessment of Emissions and Cost Impacts of Final 2013 Revisions to the Greenhouse Gas Reporting Rule and Confidentiality Determinations for New or Substantially Revised Data Elements
--------------------------------------------------------------------------------

EPA intends to update the Global Warming Potentials (GWPs) in Table A-1 of subpart A to match the GWPs published by the Intergovernmental Panel on Climate Change (IPCC) in the 2007 Fourth Assessment Report. Additionally, EPA is finalizing technical corrections and other amendments to 30 subparts of the GHG reporting rule (40 CFR part 98).

This memorandum explains how reporters will be affected by changes to the GWPs in the GHG reporting rule and discusses the impacts of the technical corrections and other amendments. The memorandum is organized as follows:

       Section 1.0:	Background and Introduction for GWP Revisions
       Section 2.0:	Identification of Subparts Affected by the GWP Revisions in Subpart A
       Section 3.0:	Summary of Impacts and Small Entity Impacts - All Reporters
       Section 4.0:	Methodology for Estimating Impacts to Current Reporters
       Section 5.0:	Methodology for Estimating Impacts to New Reporters
       Section 6.0:	Impacts of Other Technical Corrections and Amendments
 Background and Introduction for GWP Revisions
Facilities affected by the GHG reporting rule must report their GHG emissions to EPA through the electronic Greenhouse Gas Reporting Tool (e-GGRT). In general, to calculate GHG emissions, reporters use the GWPs in Table A-1 to subpart A of the GHG reporting rule. EPA is finalizing updates to the GWPs in Table A-1 using the GWPs from the IPCC 2007 Fourth Assessment Report.
This section explains how the changes to Table A-1 will affect reporters. Two kinds of reporters are described in this memorandum:
Current reporters are those reporters that are already subject to the GHG reporting rule and have already reported their emissions to e-GGRT for the year 2010 and 2011 or for only the year 2011. Emissions data for these reporters is available through the EPA website.
New reporters are those reporters that are not currently affected by the GHG reporting rule, but would become subject to the rule as a result of the changes to Table A-1.
How GWPs Affect Emissions and Applicability to the GHG Reporting Rule
A change to the GWP for a GHG will change the calculated emissions or supply of that gas and might also change the number of facilities or suppliers that are subject to the GHG reporting rule. The number of facilities or suppliers could change because for some subparts applicability to the GHG reporting rule is based on the amount of GHG that is either consumed, generated, emitted, imported, or exported over a calendar year, expressed in carbon dioxide equivalents (CO2e). Carbon dioxide equivalent is a metric used to compare the emissions of various GHGs based on their GWP. Because different GHGs have different heat trapping capabilities and atmospheric lifetimes, they are not directly comparable without translating emissions into a common unit of measure. The GWP is a measure of the total energy that a gas absorbs over a particular period of time (usually 100 years) compared to carbon dioxide, which has a GWP of 1.0. The CO2e for a specific gas is derived by multiplying the mass of the gas by the associated GWP. For example, methane currently has a GWP of 21. A facility that emits 1,000 tons of CO2 emits 1,000 tons per year of CO2e. A facility that emits 1,000 tons of methane emits 21,000 tons per year of CO2e.
Based on revised radiative forcing research, the IPCC in the 2007 Fourth Assessment Report updated the GWP values for the following compounds: methane, nitrous oxide, certain hydrofluorocarbons, perfluorinated compounds, and fluorinated ethers, substances controlled by the Montreal protocol, and certain hydrocarbons and other compounds with direct warming effects. The revised GWP values by IPCC represent an increase in the GWP for methane (CH4), a slight decrease for nitrous oxide (N2O), an increase for 10 fluorinated gases, and a decrease for three fluorinated gases. The GWP for all other GHGs currently on Table A-1 are unchanged. The GHGs that are covered by the GHG reporting rule are carbon dioxide (CO2), CH4, N2O, sulfur hexafluoride (SF6), hydrofluorocarbons, perfluorocarbons, and other fluorinated GHGs (which include fluorinated ethers). The GHG reporting rule does not require reporting of emissions of the Montreal protocol substances or the hydrocarbons with direct effects (dimethylether, methylene chloride, and methyl chloride). Appendix A of this memorandum lists the compounds covered by the GHG reporting rule along with the original GWPs and the final GWP revisions.
Currently, some source categories under 40 CFR part 98 provide calculation methodologies and reporting requirements for fluorinated greenhouse gases (F-GHGs) or fluorinated heat transfer fluids (F-HTFs) for which GWPs were not available in the IPCC assessment reports or other scientific assessments at promulgation. 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)). Those F-GHGs or F-HTFs whose GWPs are currently not listed in Table A-1 are not included in threshold calculations for applicability or in the CO2e totals reported by facilities and suppliers, but are instead reported in metric tons of substance emitted or supplied (40 CFR 98.3(c)(4)).
Revisions to the GWPs affect the calculation of CO2e from facility emissions, 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.
In this memorandum, the impacts of the revised GWPs in Table A-1 to subpart A are evaluated on the emissions reported and on the emissions from new reporters that would be required to report under each subpart if the changes are incorporated into the reporting rule. The compliance costs that would be incurred by these new reporters are also estimated. The methodology used to identify the subparts for which emissions calculated as CO2e would change is described in section 2.0 of this memorandum. A summary of cost and emissions impacts due to the revisions is provided in section 3.0. The methodologies used to determine cost and emissions impacts to current reporters are described in section 4.0. The methodologies used to determine cost and emissions impacts to new reporters are described in section 5.0.
 Identification of Subparts Affected by the GWP Revisions in subpart A
Current Reporters
Current reporters are those reporters that are already affected by the GHG reporting rule and have already reported their GHG emissions to e-GGRT (or are expected to report their estimated emissions to e-GGRT in the near future). Each GHG source category is identified in Table 2-1.
Table 2-1. GHG Reporting Rule Subpart and Source Category
Subpart
GHG Source Category
                                       C
 General Stationary Fuel Combustion Sources
                                       D
 Electricity Generation
                                       E
 Adipic Acid Production
                                       F
 Aluminum Production
                                       G
 Ammonia Manufacturing
                                       H
 Cement Production
                                       I
Electronics Manufacturing
                                       K
 Ferroalloy Production
                                       L
Fluorinated Gas Production
                                       N
 Glass Production
                                       O
 HCFC-22 Production and HFC-23 Destruction
                                       P
 Hydrogen Production
                                       Q
 Iron and Steel Production
                                       R
 Lead Production
                                       S
 Lime Manufacturing (non-CEMS)
                                       T
Magnesium Production
                                       U
 Miscellaneous Uses of Carbonate
                                       V
 Nitric Acid Production
                                       W
Petroleum and Natural Gas Systems
                                       X
 Petrochemical Production
                                       Y
 Petroleum Refineries
                                       Z
 Phosphoric Acid Production
                                      AA
 Pulp and Paper Manufacturing
                                      BB
 Silicon Carbide Production
                                      CC
 Soda Ash Manufacturing
                                      DD
Use of Electric Transmission and Distribution Equipment
                                      EE
 Titanium Dioxide Production
                                      FF
Underground Coal Mines
                                      GG
 Zinc Production
                                      HH
 Municipal Solid Waste Landfills
                                      II
Industrial Wastewater Treatment
                                      JJ
Manure Management b
                                      LL
Suppliers of Coal based Liquid Fuels
                                      MM
Suppliers of Petroleum Products
                                      NN
Suppliers of Natural Gas and Natural Gas Liquids
                                      OO
Suppliers of Industrial Greenhouse Gases
                                      PP
Suppliers of Carbon Dioxide
                                      QQ
Importers / Exporters of Equipment Pre-charged with F-GHGs
                                      RR
Geologic Sequestration of Carbon Dioxide
                                      SS
Manufacture Electric Transmission and Distribution Equipment
                                      TT
Industrial Waste Landfills
                                      UU
Injection of Carbon Dioxide

The calculated emissions impacts (due to the revised GWPs) were estimated for current reporters associated with each of the GHG source categories identified in Table 2-1. The revised GWPs would have no effect on subparts with CO2 as the sole GHG (i.e., subparts MM, NN, PP, RR, and UU) because GWP is a measure of the heat trapped by specific gas(es) as compared to the heat trapped by CO2. Actual CO2 emissions are not converted to CO2e, and thus GWP has no bearing on the emissions or supply in these cases. Similarly, although CO2, CH4, and/or N2O combustion emissions are required to be reported for subparts G, R, U, Z, CC, EE, and GG, the sole emission type reported under these specific subparts is CO2 process emissions (because combustion emissions are required to be reported under subpart C). Therefore, for purposes of this memorandum, any change to combustion emissions associated with these subparts is incorporated into the impact analysis performed on subpart C; and no other impact (due to the revised GWPs) is identified for these specific subparts.
The methodology used to determine the impact of the revisions to Table A-1 for current reporters is presented in section 4.0.
New Reporters
New reporters are those reporters that are not affected by the current GHG reporting rule, but will become subject to the rule as a result of revisions to the GWPs in Table A-1. Affected subparts that might have new reporters due to revised GWPs are those that meet all three of these criteria: 1) subpart has a reporting threshold and the threshold is based on CO2e, 2) subpart requires reporting of emissions of CH4, N2O, or a F-GHG, and 3) EPA estimates that all facilities in the subpart did not previously exceed the threshold. The subparts that meet these three criteria are subparts I, T, W, HH, II, OO, and TT. The revised GWPs would not create new reporters for subparts that have no threshold, because all applicable facilities are already reporting. Similarly, categories with thresholds not based on CO2e would not create new reporters resulting from a revised GWP (e.g., for subpart FF, underground coal mines, the threshold is based on the annual volume of methane liberated from a mine). Also, if all facilities in the subpart are currently expected to exceed the 25,000 metric tons of CO2e threshold (based on an evaluation of the supporting documents for each subpart), then it was assumed that there would be no new reporters. In particular, all potential reporters under subparts K, L, and QQ (importers only) are estimated to exceed the 25,000 metric tons of CO2e threshold, so no new reporters are expected for these subparts due to the new and revised GWPs. For subpart QQ (exporters), all facilities are expected to exceed the 25,000 metric tons of CO2e threshold with the exception of exporters of SF6 electrical equipment. No additional SF6 equipment exporters are expected to exceed the 25,000 metric tons of CO2e threshold because the GWP for SF6 is decreasing.
The type of emissions required to be reported by each subpart were also considered. Subparts with CO2 as the sole emission type were eliminated; the revised GWPs would not create new reporters for these subparts because GWP is a measure of the heat trapped by specific gas(es) as compared to the heat trapped by CO2. Actual CO2 emissions are not converted to CO2e, and thus GWP has no bearing on the outputs in these cases. Subparts with emissions solely from combustion experienced such small impacts from the GWP revisions that they were not expected to trigger any additional reporters. For example, for coal burning, there is only a 0.024% increase in CO2e as a result of the change to the GWP of CH4 and N2O emissions resulting from combustion, and for natural gas, there was only a 0.005% increase. Table 2-2 provides detail for this calculation.

Table 2-2. Example Emission Calculation for 100 Million BTU/hour Combustion Unit -
Comparison of CO2e for Current and Revised GWP
                          Identifier for Methodology
                              Description and/or
                                  Methodology
                                Anthracite Coal
                                  Natural Gas
                                       A
CO2 EF (kg CO2/mmBTU)
                                    103.50
                                     53.02
                                       B
CH4 EF (kg CH4/mmBTU)
                                   1.10E-02
                                   1.00E-03
                                       C
Current GWP for CH4
                                      21
                                       D
Revised GWP for CH4
                                      25
                                       E
N2O EF (kg N2O /mmBTU)
                                   1.60E-03
                                   1.00E-04
                                       F
Current GWP for N2O
                                      310
                                       G
Revised GWP for N2O
                                      298
                                       H
Current CH4 CO2e
(B*C)
                                     0.231
                                     0.021
                                       I
Revised CH4 CO2e
(B*D)
                                     0.275
                                     0.025
                                       J
Current N2O CO2e
(E*F)
                                     0.496
                                     0.031
                                       K
Revised N2O CO2e
(E*G)
                                     0.477
                                     0.030
                                       L
Current Total CO2e
(A+H+J)
                                    104.23
                                    53.072
                                       M
Revised Total CO2e
(A+I+K)
                                    104.25
                                    53.075

Percent Change
((M-L)/L)
                                    0.024%
                                    0.005%

For subpart I, facilities that manufacture semiconductors, liquid crystal displays (LCDs), and micro-electromechanical systems (MEMS) must calculate annual emissions for threshold applicability purposes considering only the gases for which default emission factors are provided in Table I-1 to subpart I. Facilities must account for F-HTF emissions as a percentage of the total annual production process emissions at a facility (calculated using the default factors in Table I-1). Table I-1 does not include F-GHGs affected by the changes to Table A-1, therefore the applicability for these facilities will not change.
Table 2-3 lists all of the GHG reporting rule subparts and the rationale for including or excluding the subpart in the new reporter impact analysis described in section 5.0. As noted in Table 2-3 all facilities subject to subparts L and QQ are expected to be above the reporting threshold, therefore there are no additional facilities that will be required to report. Emissions of fluorinated gases for subpart DD (Use of Electric Transmissions and Distribution Equipment) and subpart SS (Electrical Equipment Manufacture) were reported as only SF6 emissions; therefore, the assignment of GWPs for other F-GHGs would have no effect on reporters under subpart DD and SS. For subpart T (Magnesium Production), the primary gas emitted is SF6. Because the GWP for SF6 is decreasing, the calculated emissions would decrease, and no additional facilities would be required to report as a result. For subpart OO (Industrial GHG Suppliers), EPA identified the potential of three additional reporters due to the revisions to the GWPs in Table A-1.
Table 2-3. Rationale for GHG Subpart Selection for New Reporter Impact Analysis
                                    Subpart
              Excluded / Included in New Reporter Impact Analysis
                                   Rationale
C- Stationary Combustion
                                   Excluded
Combustion emissions only
D- Electricity Generation
                                   Excluded
Threshold not based on CO2e
E - Adipic Acid
                                   Excluded
All facilities must report - no threshold
F - Aluminum
                                   Excluded
All facilities must report - no threshold
G - Ammonia
                                   Excluded
All facilities must report - no threshold
H - Cement
                                   Excluded
All facilities must report - no threshold
I - Electronics
                                   Included
Threshold category that emits mainly fluorinated GHG
K -Ferroalloy
                                   Excluded
All facilities in subpart expected to be above threshold
L - Fluorinated Gas
                                   Excluded
All facilities in subpart expected to be above threshold
N - Glass
                                   Excluded
CO2 and/or combustion emissions only
O - HCFC-22, HFC-23
                                   Excluded
Threshold not based on CO2e
P - Hydrogen
                                   Excluded
CO2 and/or combustion emissions only
Q - Iron & Steel
                                   Excluded
CO2 and/or combustion emissions only
R - Lead
                                   Excluded
CO2 and/or combustion emissions only
S - Lime
                                   Excluded
All facilities must report - no threshold
T - Magnesium
                                   Included
Threshold category that emits mainly fluorinated GHG
U - Carbonate
                                   Excluded
CO2 emissions only
V - Nitric Acid
                                   Excluded
All facilities must report - no threshold
W - Petroleum & Natural Gas
                                   Included
Threshold category that emits methane
X - Petrochemicals
                                   Excluded
All facilities must report - no threshold
Y - Refineries
                                   Excluded
All facilities must report - no threshold
Z - Phosphoric Acid
                                   Excluded
All facilities must report - no threshold
AA - Pulp & Paper
                                   Excluded
All facilities in subpart expected to be above threshold
BB - Silicon Carbide
                                   Excluded
All facilities must report - no threshold
CC - Soda Ash
                                   Excluded
All facilities must report - no threshold
DD - Electrical Transmission
                                   Excluded
Threshold not based on CO2e
EE - Titanium Dioxide
                                   Excluded
All facilities must report - no threshold
FF - Underground Coal Mines
                                   Excluded
Threshold not based on CO2e
GG - Zinc
                                   Excluded
CO2 and/or combustion emissions only
HH - MSW Landfills
                                   Included
Threshold category that emits mostly methane
II - Industrial Wastewater
                                   Included
Threshold is based on methane generation
JJ - Manure Mgmt
                                   Excluded
Subpart is not being implemented
LL - Coal-based Liquid Fuels Suppliers
                                   Excluded
CO2 is the only GHG reported
MM - Petroleum Suppliers
                                   Excluded
CO2 is the only GHG reported
NN - Natural Gas Suppliers
                                   Excluded
Threshold not based on CO2e
OO - Industrial GHG Suppliers
                                   Included
Importers/exporters have threshold for fluorinated GHG
PP - CO2 Suppliers
                                   Excluded
CO2 is the only GHG reported
QQ - Importers / Exporters of F-gases in pre-charged equipment or closed-cell foams
                                   Excluded
Threshold category and all importers/exporters in the category are expected to be above threshold[a]
RR - Geologic Sequestration
                                   Excluded
All facilities must report - no threshold
SS - Electrical Equipment
                                   Excluded
Threshold not based on CO2e
TT - Industrial Waste Landfills
                                   Included
Threshold is based on methane generation
UU - CO2 Injection
                                   Excluded
All facilities must report - no threshold
a	Some facilities with SF6 containing electrical equipment were below the threshold; SF6 GWP is decreasing, therefore no additional affected facilities.
Summary of Impacts and Small Entity Impacts  -  All Reporters
Summary of Emissions and Cost Impacts
The impacts to the quantity of CO2e reported and costs resulting from the GWP revisions for each subpart are presented in two tables:
         * Table 3-1 includes a summary of impacts to the quantity of CO2e reported for all reporters; and
         * Table 3-2 includes a summary of the cost impacts for the new reporters anticipated.
      These tables include the estimated changes to the number of affected facilities and expected CO2e reported.
Table 3-1. 2011 Reporters - Summary of Impacts Due to GWP Revisions for Source Categories Reporting in 2011
                                    Subpart
               Number of Reporters Affected by GWP Revisions[a]
Expected Total CO2e Reported After GWP Revisions
(metric tons CO2e per year)[b]
     Total Change in CO2e Due to GWP Revisions
(metric tons CO2e per year)
C  -
Stationary Combustion
                                    5,426
                                 618,943,387
                                   145,552
D  -
Electricity Generation
                                    1,258
                                2,134,344,533
                                   270,863
E  -
Adipic Acid
                                      3
                                  10,200,670
                                   (410,765)
F  -
Aluminum
                                      10
                                   7,635,878
                                    170,321
G -
Ammonia
                                      0
                                  14,012,704
                                      0
H  -
Cement
                                      94
                                  52,854,721
                                    4,764
I  -
Electronics
                                      53
                                  3,720,318
                                   593,554
K  -
Ferroalloy
                                      10
                                  2,280,270
                                    1,913
L  -
Fluorinated Gas
                                      16
                                   6,913,066
                                    812,347
N  -
Glass
                                     110
                                  2,074,305
                                      4
O  -
HCFC-22, HFC-23
                                      5
                                   8,771,214
                                   1,837,214
P  -
Hydrogen
                                     103
                                  32,958,021
                                      10
Q  -
Iron & Steel
                                     128
                                  30,664,338
                                     (28)
R  -
Lead
                                      0
                                   736,087
                                      0
S  -
Lime
                                      73
                                  16,153,152
                                     162
T  -
Magnesium
                                      9
                                   2,092,420
                                   (96,541)
U  -
Carbonate
                                      0
                                   122,216
                                      0
V  -
Nitric Acid
                                      36
                                  10,888,395
                                   (438,459)
W  -
Petroleum & Natural Gas
                                    1,646
                                 158,187,220
                                  18,289,767
X  -
Petrochemicals
                                      64
                                  9,302,398
                                    11,872
Y  -
Refineries
                                     145
                                  56,471,884
                                   114,025
Z  -
Phosphoric Acid
                                      0
                                  1,438,428
                                      0
AA  -
Pulp & Paper
                                     110
                                  7,495,513
                                    53,421
BB  -
Silicon Carbide
                                      1
                                   139,994
                                    2,398
CC  -
Soda Ash
                                      0
                                  1,341,446
                                      0
DD  -
Electrical Transmission
                                      97
                                  3,688,839
                                   (177,970)
EE  -
Titanium Dioxide
                                      0
                                  1,346,279
                                      0
FF  -
Underground Coal Mines
                                     146
                                  32,896,721
                                  5,263,475
GG  -
Zinc
                                      0
                                   816,621
                                      0
HH  -
MSW Landfills
                                    1,259
                                 109,562,567
                                  2,562,567
II  -
Industrial Wastewater
                                     153
                                  4,499,394
                                   769,883
JJ  -
Manure Mgmt
                                      0
                                      0
                                      0
LL  -
Coal-based Liquid Fuels Suppliers
                                      0
                                    --[c]
                                      0
MM  -
Petroleum Suppliers
                                      0
                                    --[c]
                                      0
NN  -
Natural Gas Suppliers
                                      0
                                     -- c
                                      0
OO  -
Industrial GHG Suppliers
                                     170
                                     -- c
                                  44,060,000
PP  -
CO2 Suppliers
                                      0
                                     -- c
                                      0
QQ  -
Importers / Exporters of F-gases in pre-charged equipment or closed-cell foams
                                      34
                                     -- c
                                    -- [d]
RR  -
Geologic Sequestration
                                      0
                                      0
                                      0
SS  -
Electrical Equipment
                                      5
                                   293,767
                                   (14,173)
TT  -
Industrial Waste Landfills
                                     192
                                  10,581,216
                                  2,129,795
UU  -
CO2 Injection
                                      0
                                     -- c
                                      0
[a] Includes new reporters who would be required to submit an annual report due to the changes to GWPs in Table A-1.
[b] Expected total CO2e reported includes the change in emissions for existing reporters and from new reporters who would be required to submit an annual report due to the changes to GWPs in Table A-1 for the source category identified. The expected total CO2e reported does not include emissions from reporters who may be required to newly submit an annual report for multiple source categories.
[c] Not included for subparts for which totals include reporting of CBI.
[d] Not included for subparts for which totals include reporting of CBI. Assume a nominal 16% increase over current CO2e reported. This estimated increase equals the average of the percent change in GWP for the HFCs, and PFCs and SF6.

Table 3-2. Summary of Cost Impact Due to the GWP Revisions
                                    Subpart
                 Number of New Reporters Due to GWP Revisions
                      Incremental CO2e for New Reporters
                          (metric tons CO2e per year)
                                  First Year
                                  Cost Impact
                                    ($/yr)
                           Incremental Cost Impact
                                    ($/yr)
I  -
Electronics
                                       4
                                    18,076
                                    129,500
                                    237,000
T  -
Magnesium
                                       0
                                       0
                                       0
                                       0
W  -
Petroleum & Natural Gas
                                      99
                                   2,572,881
                                   1,648,000
                                    772,000
HH  -
MSW Landfills[a]
                                      57
                                   1,560,000
                                    246,000
                                    182,200
II  -
Industrial Wastewater
                                       2
                                    59,500
                                    10,800
                                    10,500
OO  -
Industrial GHG Suppliers
                                       3
                                    75,000
                                    13,100
                                    10,000
TT  -
Industrial Waste Landfills[a]
                                      19
                                    520,000
                                    112,000
                                    98,050
                                     Total
                                      184
                                   4,805,457
                                   2,195,400
                                   1,316,750
[a] Subpart HH cost impact includes average annualized reporting costs for 43 closed landfills that will exit the reporting program later than expected. Similarly, subpart TT cost impact includes average annualized costs for 8 closed facilities.
Small Entity Impacts
There will be a cost impact of the change to GWP for new reporters and for closed landfills that will be required to remain in the program for a longer period of time; the cost of reporting will not significantly change for those entities already required to report. A detailed discussion of the cost impact to small entities is included in the individual subpart analyses for new reporters in section 5.0. For each affected subpart that may have new reporters due to the revised GWPs, information available in supporting documents was used to identify the small businesses affected, and an impact evaluation was performed. For each subpart evaluated, it was determined that there is not a significant impact on a substantial number of small businesses.
METHODOLOGY FOR estimating impacts to CURRENT REPORTERS
Emissions Impacts (current reporters)
The level of increased calculated CO2e that will be reported by existing reporters (due to the revised GWPs) was estimated by adjusting the 2011 reported GHG emissions using the new GWP for each reported compound. The reported emissions of each GHG (CO2, CH4, N2O, etc.) were extracted from the most recent data reported to EPA (US EPA 2013a). The total number of facilities reporting under each subpart was defined and the total reported emissions of each GHG for each subpart were calculated. The total reported mass emissions of each GHG were multiplied by the current GWP (see 40 CFR part 98, subpart A, Table A-1) to determine the original reported emissions of each GHG in metric tons of CO2e. To calculate the emissions impacts in metric tons of CO2e (due to the revised GWPs) for each source category, the mass emissions for each GHG were multiplied by the difference between the existing GWP and the revised GWPs from the IPCC AR4. For some subparts, Table 3-1 shows no change in the expected CO2e reported emissions from the changes to the GWPs. Although CO2, CH4, and N2O combustion emissions are required to be reported for subparts G, R, U, Z, CC, EE, and GG, the sole emission type reported under these specific subparts is CO2 process emissions (because combustion emissions are required to be reported under subpart C and there are no CH4 or N2O process emissions for these subparts). Therefore, for purposes of this analysis, any change to combustion emissions associated with these subparts is incorporated into the impact analysis performed on subpart C; and no other impact (due to the revised GWPs) is identified for these specific subparts.
For several subparts that report fluorinated gases, emissions information was not available for the individual compounds.  Emissions estimates for these subparts are discussed in more detail in sections 4.1.1 and 4.1.2.
Subpart I Emissions Impacts (current reporters)
In the original threshold analysis (U.S. EPA, 2010a), EPA identified the number of facilities that would be covered under subpart I with a 25,000 metric tons CO2e emissions-based threshold. For LCDs and PVs, EPA calculated the total annual emissions, in metric tons of CO2e, for each facility using the IPCC Tier 1 default emissions factors. The emissions factors were converted to metric tons of CO2e basis by multiplying the factors by the appropriate GWP value. EPA used the results to estimate the magnitude of emissions from those facilities expected to emit greater than the 25,000 metric tons CO2e threshold. The number of, and emissions from, MEMS facilities were calculated using the same procedure, but with an emission factor developed by the EPA (U.S. EPA, 2010b).
In the original analysis, EPA used the same procedure described above (i.e., default IPCC Tier 1 factors) to determine the number of semiconductor facilities that were expected to emit greater than the 25,000 metric tons CO2e threshold. To estimate the magnitude of emissions from those semiconductor facilities expected to emit greater than the threshold, EPA used emission estimations that were derived using outputs from the EPA PFC Emissions Vintaging Model (PEVM), as well as the EPA PFC Reduction/Climate Partnership for Semiconductors partner and non-partner shares of U.S. emissions. EPA also accounted for heat transfer fluid emission estimates by assuming such emissions were equal to 11 percent of total clean and etch emissions at a facility.
To determine the level of increased emissions that will be reported by existing reporters under subpart I due to the revised GWPs, the methodology from EPA's original threshold analysis was followed, but with the updated GWP values. The PEVM was not accessible to reproduce the original emission estimates; therefore, it was assumed that the PEVM based emissions would increase by the same percentage as the emissions estimated using the IPCC Tier 1 default factors and updated GWP values. This is a valid assumption because no other inputs to the PEVM are expected to change. The overall increase in emissions for this subpart is estimated at approximately 18.4 percent above the 2011 reported emissions.
Subpart L and QQ Emissions Impacts (current reporters)
Because there are 17 different fluorinated compounds for which the GWP will change by varying amounts, and a breakdown of emissions by compound was not available for subpart L or QQ, a nominal 16 percent increase was estimated as the expected increase in emissions due to revised GWPs for SF6, HFCs, and PFCs. This estimated increase equals the average of the percent change in GWP for the HFCs, and PFCs and SF6 for compounds listed in Table A-1.
Cost Impacts (current reporters)
For reporters that currently are subject to the rule for reporting, there would be no significant cost impacts resulting from the revised GWPs, with the exception of landfills expected to close after 2014 for subparts HH and TT (see the discussion in section 5.4 and section 5.7 for subpart HH and TT, respectively). Although some affected facilities and suppliers would report higher CO2e emissions in their annual GHG report, using the revised GWPs would not affect the cost of monitoring and recordkeeping and would not materially affect the cost for calculating emissions.
References for Section 4.0
U.S. EPA, 2013a.  2011 Greenhouse Gas Reporting Program Data ( reported to EPA by facilities as of February 17, 2013).
U.S. EPA, 2012b. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2010, April 2012. http://epa.gov/climatechange/Downloads/ghgemissions/US-GHG-Inventory-2012-Main-Text.pdf
U.S. EPA, 2010a. Subpart I Detailed Threshold Analysis. See Docket ID: EPA-HQ-OAR-2009-0927-0158. November 2010.
U.S. EPA, 2010b. Technical Support Document for Process Emissions from Electronics Manufacture (e.g., Micro-Electro-Mechanical Systems, Liquid Crystal Displays, Photovoltaics, and Semiconductors): Proposed Rule for Mandatory Reporting of Greenhouse Gases. Revised November 2010. Available at: http://www.epa.gov/climatechange/emissions/downloads10/Subpart-I_TSD.pdf

 Methodology for estimating impacts to new reporters
The methodologies used to determine cost and emissions impacts to new reporters (due to the revised GWPs in Table A-1 to subpart A) are described in this section. Summaries of the methodology, reference documents, and any assumptions specific to each subpart (that are identified as not currently being affected by the GHG reporting rule, but will become subject to the rule as a result of revisions to the GWPs in Table A-1) are documented in the following individual subpart subsections. Each of these individual subpart subsections are further organized into smaller sections that discuss the following topics:  identifying new reporters; estimating emissions impacts; estimating cost impacts; small entities impacts; summary of impacts; and references.
Subpart I
Subpart I requires reporting of fluorinated GHGs from the following source categories that emit 25,000 metric tons CO2e per year or more: electronics manufacturing including manufacture of semiconductors, PVs, LCDs, and MEMS. Changes to the following GWPs affect subpart I: CF4, C2F6, CHF3, C3F8, SF6, C6F14 (semiconductors); SF6 (MEMS); CF4, SF6 (LCDs); and CF4, C2F6 (PVs).  As discussed in section 2.2, subpart I reporters must calculate annual emissions for threshold applicability purposes considering only the gases for which default emission factors are provided in Table I-1. Although facilities must also account for F-HTF emissions, these emissions are estimated as a percentage of the total annual production process emissions at a facility (calculated based on gases in Table I-1).
Subpart I (identifying new reporters)
In the original threshold analysis (U.S. EPA, 2010a), EPA identified the number of facilities that would be covered under subpart I with a 25,000 metric tons CO2e emissions-based threshold. The original threshold analysis included a list of facilities for each product type (i.e., semiconductors, MEMS, LCDs, and PVs) and estimates of substrate area processed and total annual emissions for each facility.
For LCDs and PVs, EPA calculated the total annual emissions, in metric tons of CO2e, for each facility using the IPCC Tier 1 default emissions factors. The emissions factors were converted to metric tons of CO2e basis by multiplying the factors by the appropriate GWP value. EPA evaluated the results to determine which facilities were expected to emit greater than the 25,000 metric tons CO2e threshold. EPA also used the results to estimate the magnitude of emissions from those facilities expected to emit greater than the 25,000 metric tons CO2e threshold. The number of, and emissions from, MEMS facilities were calculated using the same procedure, but with an emission factor developed by the EPA (U.S. EPA, 2010b).
In the original threshold analysis, EPA used the same procedure described above (i.e., default IPCC Tier 1 factors) to determine the number of semiconductor facilities that were expected to emit greater than the 25,000 metric tons CO2e threshold. EPA did not consider emissions from heat transfer fluids when determining which semiconductor facilities would meet the threshold. To estimate the magnitude of emissions from those semiconductor facilities expected to emit greater than the threshold, EPA used emission estimations that were derived using outputs from the EPA PEVM, as well as the EPA PFC Reduction/Climate Partnership for Semiconductors partner and non-partner shares of U.S. emissions. EPA also accounted for heat transfer fluid emission estimates by assuming such emissions were equal to 11 percent of total clean and etch emissions at a facility.
To determine the additional number of facilities that would meet the threshold due to changes to the GWP values in subpart A, the methodology from EPA's original threshold analysis was followed, but with the updated GWP values. The PEVM was not accessible to reproduce the original emission estimates; therefore, it was assumed that the PEVM based emissions would increase by the same percentage as the emissions estimated using the IPCC Tier 1 default factors and updated GWP values. This is a valid assumption because no other inputs to the PEVM are expected to change.
Table 5-1 identifies the number of new subpart I reporters that will become subject to the rule as a result of revisions to the GWPs in Table A-1.
                      Table 5-1. New Subpart I Reporters
                                 Facility Type
                 Number of New Reporters Due to GWP Revisions
                              Large Semiconductor
                                       0
                            Non-Large Semiconductor
                                       4
                               Non-Semiconductor
                                       0
                                     Total
                                       4

Subpart I (estimating emissions impacts)
An emissions increase would be expected from new subpart I reporters that will become subject to the rule as a result of revisions to the GWPs in Table A-1. This emissions increase was determined using the methodology from EPA's original threshold analysis (U.S. EPA, 2010a), but with the updated GWP values. It was assumed that the PEVM-based emissions would increase by the same percentage as the emissions estimated using the IPCC Tier 1 default factors and updated GWP values. Table 5-2 identifies the emissions impact from new subpart I reporters.
           Table 5-2. Emissions Impact From New Subpart I Reporters
                                 Facility Type
                 Incremental CO2e Emissions for New Reporters
                        (metric tons of CO2e per year )
                              Large Semiconductor
                                       -
                            Non-Large Semiconductor
                                    18,100
                               Non-Semiconductor
                                       -
                                     Total
                                    18,100

Subpart I (estimating cost impacts)
Costs were calculated by multiplying the average costs per facility and the number of new facilities estimated to be subject to subpart I (from revising the GWPs). Average costs per facility were calculated by dividing total cost by the number of respondents identified in the most recent information collection request for the GHG reporting program (U.S. EPA, 2013).
Appendices J and L to the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to obtain first year average cost per facility that is incurred from reporting under subpart I. Cost details from Exhibit 6.1 of the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to determine the subsequent years average cost per facility. These average costs per facility include labor costs (i.e., the cost of labor by facility staff to meet the rule's information collection requirements) and non-labor (capital, and operation and maintenance) costs. Additional details of the data, methods, and assumptions underlying these costs are documented in the most recent information collection request (U.S. EPA, 2013).
Table 5-3 shows first and subsequent year average cost per facility subject to subpart I.
Table 5-3. Annual Average Cost Per Facility Subject to Subpart I
                                    Subpart
                        Total Number of Respondents [a]
                                  Total Cost
                               (2011$ per year)
                               Cost Per Facility
                               (2011$ per year)

                                First Year [b]
                             Subsequent Years [a]
                                First Year [b]
                             Subsequent Years [a]
I  -
Electronics
                                      94
                                   3,042,000
                                   5,567,000
                                    32,400
                                    59,200
[a] This data was extracted from Exhibit 6.1 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). EPA is currently updating certain provisions of subpart I. Those updates are reflected in the ICR for that rulemaking effort.
[b] The first year total cost are from the current cost & burden table identified as "First-Year Burden & Cost" in Appendix J-3 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013) and includes $80.91 from the current burden & cost table identified as "First Reporting Year" table of Appendix L-2 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). The $80.91 is the cost contributed to provisions of information on parent companies, NAICS codes, and whether emissions are from cogeneration. These costs were updated to 2011 dollars using the Bureau of Labor Statistics Employment Cost Index and the Chemical Engineering Plant Cost Index (CEPCI).

By revising the GWP values in subpart A, four additional non-large semiconductor facilities will be required to report under subpart I. The first year cost for these four facilities will be approximately $129,500 per year (4 x $32,365 = $129,500), and the annualized industry wide cost is approximately $237,000 per year (4 x $59,200 = $236,800).
Because EPA has recently published the "Final Amendments and Confidentiality Determinations for Subpart I" (signed by the Administrator on August 16, 2013), it is assumed that the costs presented above are overly conservative. The final amendments to subpart I are expected to reduce the cost to reporters. The updated costs for subpart I have been submitted for approval to the Office of Management and Budget.
Subpart I Small Entity Impacts (new reporters)
In the subpart I Economic Impact Analysis (U.S. EPA, 2010c), EPA originally assessed the impact of complying with subpart I requirements on all small entities in the electronics manufacturing industry by calculating a cost-to-sales ratio for six enterprise size ranges (i.e., 1 to 20 employees, 20 to 99 employees, 100 to 499 employees, 500 to 749 employees, 750 to 999 employees, and 1,000 to 1,499 employees) using the average total annualized mandatory reporting costs to the average annual sales receipts for each establishment. The results of this analysis are represented in Table 14 of the preamble for the publication of the subpart I rule (75 FR 74811, December 1, 2010).
Based on this analysis, EPA concluded that subpart I will not have a significant economic impact on a substantial number of small entities (U.S. EPA, 2010c). EPA made this determination assuming that all entities in the industry would report (including those above and below the reporting threshold), resulting in a conservatively high analysis. EPA determined that no significant small business economic impacts were expected to occur. The analysis showed that the cost-to-sales ratio for all entity sizes except for the smallest sized enterprises was less than 1 percent. EPA concluded that although the cost-to-sales ratio for the 1 to 20 employee range for semiconductor and related device manufacturing was greater than one percent (i.e., 1.16 percent); facilities with emissions greater than 25,000 metric tons CO2e per year are unlikely to be included in the 1 to 20 employees size category (U.S. EPA, 2010c).
The revised emission estimates (using the revised GWPs) place the 4 new affected facilities above the 25,000 metric tons CO2e threshold. In addition, the emission estimates for the 4 facilities in the original threshold analysis were just slightly below the threshold (3 to 10 percent). Based on EPA's conclusion that facilities with emissions greater than 25,000 metric tons CO2e per year are unlikely to be included in the 1 to 20 employees size category, the 4 additional facilities are not expected to be included in the 1 to 20 employees size category either. As a result, the changes to the GWPs will not have a significant impact on a substantial number of small entities.
Subpart I (summary of impacts)
Table 5-4 summarizes the impacts of updating the GWP values in Table A-1 to subpart A, on new facilities required to report subpart I emissions.
Table 5-4. New Reporters -- Summary of Subpart I Impacts Due to the Revisions to GWPs
                                 Facility Type
                 Number of New Reporters Due to GWP Revisions
                 Incremental CO2e Emissions for New Reporters
                      (metric tons of CO2e per year ) [a]
                   Incremental Cost Impact For New Reporters
                               (2011$ per year)

                                First Year [a]
                             Subsequent Years [a]
                              Large Semiconductor
                                       0
                                       -
                                       -
                                       -
                            Non-Large Semiconductor
                                       4
                                    18,100
                                    129,600
                                    237,000
                               Non-Semiconductor
                                       0
                                       -
                                       -
                                       -
                                     Total
                                       4
                                    18,100
                                    129,600
                                    237,000
[a] Values rounded.
References for Subpart I
U.S. EPA, 2010a. Subpart I Detailed Threshold Analysis. See Docket ID: EPA-HQ-OAR-2009-0927-0158. November 2010.
U.S. EPA, 2010b. Technical Support Document for Process Emissions from Electronics Manufacture (e.g., Micro-Electro-Mechanical Systems, Liquid Crystal Displays, Photovoltaics, and Semiconductors): Proposed Rule for Mandatory Reporting of Greenhouse Gases. See Docket ID: EPA-HQ-OAR-2009-0927-0195. Revised November 2010.
U.S. EPA, 2010c. Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions F-Gases: Subparts I, L, DD, QQ, SS Final Report. See Docket ID: EPA-HQ-OAR-2009-0927-0179. November 2010.
U.S. EPA, 2013.  Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program.  OMB Control No. 2060-0629. EPA ICR No. 2300.10. May 2013.
Subpart T
Magnesium production and processing facilities are defined as any site where magnesium metal is produced through smelting (including electrolytic smelting), refining, or remelting operations, or any site where molten magnesium is used in alloying, casting, drawing, extruding, forming, or rolling operations. Each facility must report total annual emissions for each of the following cover or carrier gases used in magnesium production or processing: SF6, HFC-134a, the fluorinated ketone FK 5-1-12, CO2, and any other fluorinated GHG as defined in the greenhouse gas reporting rule.
Subpart T (identifying new reporters)
In the 2010 Threshold Analysis for the magnesium production category for the original rule (U.S. EPA, 2009), EPA identified 13 nationwide facilities in the magnesium production and processing source category. EPA evaluated a range of threshold options for these facilities, utilizing 2006 annual reporting data on metal production and SF6 consumption provided through the EPA's SF6 Emission Reduction Partnership for the Magnesium Industry as the basis for the analysis. These included emission-based thresholds of 1,000, 10,000, 25,000 and 100,000 metric tons CO2e, as shown in Table 5-5, and capacity-based thresholds equivalent to these. The July 12, 2010 final rule established an emissions threshold of 25,000 metric tons CO2e, which was estimated to cover all currently operating U.S. primary and secondary magnesium ingot producers and most die casters, accounting for over 99 percent of emissions from these source categories. This threshold analysis excluded small die casting facilities as well as facilities that performed other types of casting, which represent only a small fraction of total emissions from this source category. The emissions threshold of 25,000 metric tons CO2e established in the final rule was equal to emissions of 1,046 kg of SF6; 19,231 kg of HFC - 134a; or 25,000,000 kg of CO2 (based on the GWP values established in Table A-1 to subpart A of part 98) (U.S. EPA, 2009).
Table 5-5. Threshold Analysis for Subpart T  -  Magnesium Production
Emission Threshold Level (metric tons CO2e/yr)
Total National Emissions
(metric tons CO2e/yr)
Total Number of Facilities
Emissions Covered
Facilities Covered

metric tons CO2e/yr
Percent
Facilities
Percent
                                     1,000
                                   3,200,000
                                      13
                                   2,954,559
                                      92%
                                      13
                                    100.0%
                                    10,000
                                   3,200,000
                                      13
                                   2,939,741
                                      92%
                                      11
                                     85.0%
                                    25,000
                                   3,200,000
                                      13
                                   2,939,741
                                      92%
                                      11
                                     85.0%
                                    100,000
                                   3,200,000
                                      13
                                   2,872,982
                                      90%
                                       9
                                     69.0%

Facility-level information from the threshold analysis for the 2010 final rule was not published in Docket No. EPA - HQ - OAR - 2008 - 0508 due to confidentiality concerns. Therefore, for purposes of this memorandum, the incremental impacts to the magnesium production industry were estimated based on the available aggregate data. In order to estimate the source category impacts from revising the GWPs in Table A-1 to subpart A of part 98, the 2004 GWPs reflected in Table A-1 to subpart A were compared to the revised GWPs to determine the increase for each reported pollutant.
Only SF6 and HFC-134a have been evaluated for the purposes of estimating the impacts of the revised GWPs. Table 5-6 lists the pollutants and associated increase in GWP for each chemical. Emissions of the fluorinated ketone FK 5 - 1 - 12, although required to be reported under 40 CFR 98.202, are not included in this threshold analysis, because this gas has a GWP of 1.8 and is not expected to significantly impact reported emissions.
Table 5-6. Increase in GWP for Pollutants Associated with
Magnesium Production and Processing
                                Pollutant Name
                                    CAS No.
                               Chemical formula
                      GWP in Table A-1 of the final rule
                                    New GWP
                                  % Increase
                                   FK-5-1-12
                                   756-13-8
                                 C3F7C(O)C2F5
                                      NA
                                      1.8
                                       -
                                  HFC - 134a
                                 811 - 97 - 2
                                    CH2FCF3
                                     1,300
                                     1,430
                                      10
                                      SF6
                                 2551 - 62 - 4
                                      SF6
                                    23,900
                                    22,800
                                      -5

As shown in Table 5-6, emissions from facilities utilizing SF6 that meet the current 25,000 metric tons CO2e threshold would decrease as a result of the revised GWP for SF6. For these facilities, this decrease would be significant only if the revisions to the GWP reduced their annual emissions to less than 25,000 metric tons CO2e for 5 consecutive years (per 40 CFR 98.2(i)). Therefore, the impacts of these emissions reductions were not assessed in this memorandum. Facilities utilizing the cover gas HFC-134a could potentially become subject to the GHG reporting rule if the increase in the GWP brought facility-wide emissions above 25,000 metric tons CO2e. This would include only facilities with current total facility emissions between 22,500 metric tons CO2e and 25,000 metric tons CO2e.
The aggregate data from the 2010 Threshold Analysis showed that the 11 facilities exceeding the 10,000 metric tons CO2e threshold also exceeded the 25,000 metric tons CO2e threshold (see Table 5-5). Based on these data, there would be no facilities meeting the 10,000 metric tons CO2e threshold that would be affected by the revised GWPs, because these facilities already exceed the 25,000 metric tons CO2e threshold. Only two facilities not meeting the 25,000 metric tons CO2e threshold could potentially be affected by an increase in the GWPs; these two facilities did not exceed the 10,000 metric tons CO2e threshold at the time subpart T was finalized in July 2010, therefore it is unlikely that these facilities would exceed 25,000 tons CO2e per year with the GWP change.
Updated data from the SF6 Emission Reduction Partnership program for the 2010 reporting year were used to verify the conclusion that no additional facilities will be impacted by the revised GWPs. EPA operated the SF6 Emission Reduction Partnership to encourage industry to reduce emissions of SF6 and eliminate the usage of SF6 as a cover gas. As a result, facilities have increased usage of FK 5 - 1 - 12 (proposed GWP=1.8) and HFC-134a (proposed GWP=1,430) as cover gases, resulting in an overall reduction in industry GHG emissions. Facilities reporting under the SF6 Emission Reduction Partnership include major emitters. Non-reporting facilities include smaller facilities (e.g., sand casting or small die casters) whose emissions are expected to be less than the threshold reporting level. The Partnership data is limited because not all facilities consistently report gas use each year; additionally, process data reported under the Partnership has historically been considered confidential. For this analysis, only aggregate facility-level emissions based on SF6 usage were available; emissions data from other gas usage were not available. Based on the 2010 SF6 Partnership data, 16 facilities reported, and 11 facilities reported use of SF6. This is close to the original estimate of 13 processing facilities in the 2010 Threshold Analysis, which was based on 2006 emission estimates. The reported 2010 SF6 emissions are summarized in Table 5-7.
Table 5-7. 2010 SF6 Emissions Reported through the SF6 Partnership
                          Total Number of Facilities
SF6 Emissions Level
(metric tons CO2e/yr)
                     Facilities Meeting SF6 Emission Level
                                      16
                                     0-999
                                      16

                                  1,000-9,999
                                      11

                                 10,000-22,499
                                       9

                                 22,500-24,999
                                       9

                                 25,000-99,999
                                       7

                                  >100,000
                                       3

For the purposes of this analysis, it was assumed that the 11 facilities reporting SF6 usage through the EPA's SF6 Magnesium Partnership are using FK 5 - 1 - 12, HFC-134a, or alternative cover gases in addition to the SF6 reported. Five facilities reported no emissions of SF6; these facilities are assumed to have used only alternative gases, such as HFC-134a or FK 5 - 1 - 12, for all production in 2010. Total SF6 emissions reported through the Partnership showed a 67% reduction in emissions from 2006. Based on the Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2012 (U.S. EPA, 2012), emissions of SF6 from magnesium production and processing in the United States were estimated to be 1.3 million metric tons CO2e in 2010, a reduction from 3.2 million metric tons CO2e in 2006. Therefore, it is anticipated that the emissions estimates summarized in Table 5-7 are a reasonable representation of gas usage in the industry following the 2010 Threshold Analysis.
There is no available data on the total gas consumption of the alternative cover gases HFC-134a or FK-5-1-12. However, the field of potential reporters was examined to determine if it could be affected if HFC-134a usage were increased. Without data on HFC-134a usage, it is unclear whether the five facilities that did not report SF6 emissions to the SF6 Partnership currently exceed or could exceed the 25,000 metric tons CO2e threshold. However, because the GWPs of HFC-134a (new GWP=1,430) and FK-5-1-12 (proposed GWP=1.8) are significantly lower than that of SF6 (new GWP = 22,800), facilities converting production gases entirely from SF6 to entirely HFC-134a or FK-5-1-12 would need to use significantly more cover gas to exceed the threshold. For example, a facility would need to use approximately 16 times more HFC-134a as a cover gas in production to meet the 25,000 metric tons CO2e threshold than if SF6 were used. Furthermore, the 2010 Partnership Data show the largest-emitting facility to have maximum SF6 emissions of ~386,000 metric tons CO2e. Assuming that total gas usage rates remained the same, if this facility were to convert all production gases to HFC-134a, the maximum GHG emissions would be just under the 25,000 metric tons CO2e threshold (386,000 * [1,430/22,800] = 24,200). Similarly, if this facility were to convert all production gases to FK-5-1-12, the maximum GHG emissions would under 31 metric tons CO2e (386,000 *[1.8/22,800]= 30.5). Therefore, facilities utilizing the cover gas FK-5-1-12 are unlikely to exceed the 25,000 metric tons CO2e threshold. Therefore, it is anticipated that the remaining facilities do not likely use sufficient HFC-134a or FK-5-1-12 to meet or exceed the 25,000 metric tons CO2e threshold, and the total number of facilities required to report would not be affected due to the revised GWPs. The total number of facilities reporting under subpart T is expected to decrease over time due to the conversion of cover gas from SF6 to HFC-134a or FK 5 - 1 - 12.
Table 5-8 identifies the number of new subpart T reporters that will become subject to the rule as a result of revisions to the GWPs in Table A-1.
                      Table 5-8. New Subpart T Reporters
                                 Facility Type
                 Number of New Reporters Due to GWP Revisions
T  -
Magnesium
                                       0

Subpart T (estimating emissions impacts)
Because there are no new facilities anticipated to be affected by the revised GWPs, there is no emissions impact from new subpart T reporters. Table 5-9 identifies the emissions impact from new subpart T reporters.
           Table 5-9. Emissions Impact From New Subpart T Reporters
                                 Facility Type
                 Incremental CO2e Emissions for New Reporters
                        (metric tons of CO2e per year )
T  -
Magnesium
                                       0

Subpart T (estimating cost impacts)
Costs were calculated by multiplying the average costs per facility and the number of new facilities estimated to be subject to subpart T (from revising the GWPs). Average cost per facility for the first year was calculated by dividing total cost by the number of respondents identified in the initial information collection request for subpart T (U.S. EPA, 2010). Average cost per facility for subsequent years was calculated by dividing total cost by the number of respondents identified in the most recent information collection request for the GHG reporting program (U.S. EPA, 2013).
Appendix A to the initial information collection request for subpart T (U.S. EPA, 2010) was used to obtain first year average cost per facility that is incurred from reporting under subpart T. Cost details from Exhibit 6.1 of the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to determine the subsequent years average cost per facility. These average costs per facility include labor costs (i.e., the cost of labor by facility staff to meet the rule's information collection requirements) and non-labor (capital, and operation and maintenance) costs. Additional details of the data, methods, and assumptions underlying these costs are documented in the information collection requests (U.S. EPA, 2010 and U.S. EPA, 2013).
Table 5-10 shows first and subsequent year average cost per facility subject to subpart T.
Table 5-10. Annual Average Cost Per Facility Subject to Subpart T
                                    Subpart
                        Total Number of Respondents [a]
                                  Total Cost
                               (2011$ per year)
                               Cost Per Facility
                               (2011$ per year)

                                First Year [b]
                             Subsequent Years [a]
                                First Year [b]
                             Subsequent Years [a]
T  -
Magnesium
                                      11
                                    123,000
                                    124,000
                                    11,100
                                    11,300
[a] This data was extracted from Exhibit 6.1 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013).
[b] This data was extracted from the "Year 1" table of Appendix A to the initial information collection request for subpart T (U.S. EPA, 2010). These costs were updated to 2011 dollars using the Bureau of Labor Statistics Employment Cost Index and the Chemical Engineering Plant Cost Index (CEPCI).

The change of GWP for HFC-134a from 1,300 to 1,400, the change of GWP for SF6 from 23,900 to 22,800, and the proposed, but not finalized, addition of a GWP of 1.8 for FK-5-1-12 is not anticipated to result in additional facilities subject to subpart T. Therefore, there are no significant rule implementation costs associated with the amendment (0 x $11,272 = $0).
Subpart T Small Entity Impacts (new reporters)
Since it is estimated that no new subpart T entities will be required to report as a result of revisions to the GWPs in Table A-1, it is anticipated that there is not a significant impact on a substantial number of small entities subject to reporting under subpart T as a result of this action.
Subpart T (summary of impacts)
Table 5-11 summarizes the impacts of updating the GWP values in Table A-1 to subpart A, on new facilities required to report subpart T emissions.
Table 5-11. New Reporters -- Summary of Subpart T Impacts Due to the Revisions to GWPs
                                 Facility Type
                 Number of New Reporters Due to GWP Revisions
                 Incremental CO2e Emissions for New Reporters
                        (metric tons of CO2e per year )
                   Incremental Cost Impact For New Reporters
                               (2011$ per year)
T  -
Magnesium
                                       0
                                       0
                                       0
References for Subpart T
U.S. EPA, 2009. Additional Methodological Information Supporting Threshold Analysis for Specific Source Categories. See Docket ID No. EPA-HQ-OAR-2008-0508-0046. March 2009.
U.S. EPA, 2010. Supporting Statement Part A: Information Collection Request for the Mandatory Reporting of Greenhouse Gases from Magnesium Production, Underground Coal Mines, Industrial Wastewater Treatment, and Industrial Waste Landfills  -  Final Rule. OMB Control No. 2060-0647. EPA ICR No. 2396.01. July 2010.
U.S. EPA, 2012. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2012. April 15, 2012. USEPA #430-R-12-001.
U.S. EPA, 2013.  Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program.  OMB Control No. 2060-0629. EPA ICR No. 2300.10. May 2013.
Subpart W
Subpart W requires petroleum and natural gas facilities to report annual CH4, CO2, and N2O emissions from specific source types that are dependent upon the industry segment. The industry segments include: NG Processing, NG Transmission, Underground NG Storage, LNG Storage, LNG Import/Export, NG Distribution, Onshore Production, and Offshore Production.
Subpart W (identifying new reporters)
The facility and source specific emissions data used to develop the subpart W Economic Impact Analysis (U.S. EPA. 2010) was used to identify the additional subpart W facilities that may be required to report using the revised GWPs.
Subpart W requires emissions reporting for CO2, CH4, and N2O; therefore, the incremental cost impacts due to the revised GWP were evaluated for only these compounds. The GWP for CO2 remains the same. The GWP for CH4 is increasing by 19%. The GWP for N2O is decreasing by 4%. These GWP changes were applied to the source specific emissions data for each subpart W facility to identify the additional facilities that would be required to report under the new GWPs. Table 5-12 identifies the number of new subpart W reporters (for each subpart W industry segment) that will become subject to the rule as a result of revisions to the GWPs in Table A-1.
Table 5-12. New Subpart W Reporters by Industry Segment
                          Subpart W Industry Segment
                 Number of New Reporters Due to GWP Revisions
                                 NG Processing
                                       2
                                NG Transmission
                                       7
                            Underground NG Storage
                                       6
                                  LNG Storage
                                       2
                               LNG Import/Export
                                       0
                                NG Distribution
                                      16
                              Onshore Production
                                     52[a]
                              Offshore Production
                                      14
                              Total (8 Segments)
                                      99
[a] 	Conservatively assumes that all emissions related to non-combustion sources are methane, and all emissions related to combustion sources are carbon dioxide.
Subpart W (estimating emissions impacts)
Table 5-13 identifies the emissions impact from new subpart W reporters by industry segment. The emissions estimates are based on the facility and source specific emissions data used to develop the subpart W Economic Impact Analysis (U.S. EPA. 2010). For LNG storage and NG distribution, the incremental expected emissions were estimated to be 450,000 metric tons CO2e by calculating the number of new facilities in these two industry segments (2+16 = 18) by 25,000 metric tons CO2e because it was assumed these facilities would only just meet the 25,000 metric tons CO2e reporting threshold.
Table 5-13. Emissions Impact From New Subpart W Reporters
                          Subpart W Industry Segment
                 Incremental CO2e Emissions for New Reporters
                        (metric tons of CO2e per year )
                                 NG Processing
                                    52,067
                                NG Transmission
                                    177,091
                            Underground NG Storage
                                    158,286
                                  LNG Storage
                                    50,000
                               LNG Import/Export
                                       0
                                NG Distribution
                                    400,000
                              Onshore Production
                                   1,372,641
                              Offshore Production
                                    362,796
                              Total (8 Segments)
                                   2,572,881

Subpart W (estimating cost impacts)
Costs were calculated by multiplying the average costs per facility and the number of new facilities estimated to be subject to subpart W (from revising the GWPs). Average costs per facility were calculated by dividing total cost by the number of respondents identified in the most recent information collection request for the GHG reporting program (U.S. EPA, 2013).
Appendices I and L to the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to obtain first year average cost per facility that is incurred from reporting under subpart W. Cost details from Exhibit 6.1 of the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to determine the subsequent years average cost per facility. These average costs per facility include labor costs (i.e., the cost of labor by facility staff to meet the rule's information collection requirements) and non-labor (capital, and operation and maintenance) costs. Additional details of the data, methods, and assumptions underlying these costs are documented in the most recent information collection request (U.S. EPA, 2013).
Table 5-14 shows first and subsequent year average cost per facility subject to subpart W.
Table 5-14. Annual Average Cost Per Facility Subject to Subpart W
                          Subpart W Industry Segment
                        Total Number of Respondents [a]
                                  Total Cost
                               (2011$ per year)
                               Cost Per Facility
                               (2011$ per year)

                                First Year [b]
                             Subsequent Years [a]
                                First Year [b]
                             Subsequent Years [a]
NG Processing
                                      289
                                   8,952,000
                                   2,324,000
                                    31,000
                                     8,000
NG Transmission
                                     1,145
                                  17,249,000
                                   7,303,000
                                    15,100
                                     6,400
Underground NG Storage
                                      133
                                   2,695,000
                                   1,122,000
                                    20,300
                                     8,400
LNG Storage
                                      33
                                    792,000
                                    270,000
                                    24,000
                                     8,200
LNG Import/Export
                                       4
                                    89,000
                                    39,200
                                    22,300
                                     9,800
NG Distribution
                                      143
                                   2,089,000
                                   1,498,000
                                    14,600
                                    10,500
Onshore Production
                                      981
                                  17,932,000
                                   7,958,000
                                    18,300
                                     8,100
Offshore Production
                                      58
                                    525,000
                                    227,000
                                     9,100
                                     3,900
[a] This data was extracted from Exhibit 6.1 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013).
[b] The first year total cost are from the current cost & burden table identified as "First-Year Burden & Cost" in Appendix I-3 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013) and includes $80.91 from the current burden & cost table identified as "First Reporting Year" table of Appendix L-2 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). The $80.91 is the cost contributed to provisions of information on parent companies, NAICS codes, and whether emissions are from cogeneration. These costs were updated to 2011 dollars using the Bureau of Labor Statistics Employment Cost Index and the Chemical Engineering Plant Cost Index (CEPCI).

By revising the GWP values in subpart A, 99 additional facilities (refer to Table 5-12 to see these facilities by subpart W industry segment) will be required to report under subpart W. The first year cost for these facilities will be approximately $1,648,000 per year [(2 x $31,000)+(7 x $15,100)+(6 x $20,300)+(2 x $24,000)+(0 x $22,300)+(16 x $14,600)+(52 x $18,300)+(14 x $9,100) = $1,648,009], and the annualized industry wide cost is approximately $772,000 per year [(2 x $8,000)+(7 x $6,400)+(6 x $8,400)+(2 x $8,200)+(0 x $9,800)+(16 x $10,500)+(52 x $8,1900)+(14 x $3,900) = $771,900].
Subpart W Small Entity Impacts (new reporters)
In the subpart W Economic Impact Analysis (U.S. EPA. 2010), EPA originally assessed the impact of complying with subpart W requirements on small entities in the petroleum and natural gas systems source category by calculating a cost-to-sales ratio for eight enterprise size ranges (i.e., all categories, 1 to 20 employees, 20 to 99 employees, 100 to 499 employees, 500 to 749 employees, less than 500 employees, 750 to 999 employees, and 1,000 to 1,499 employees) using the ratio of average total annualized reporting costs to the average annual sales receipts for each establishment. The results of this analysis are represented in Table 9 of the preamble for the publication of the subpart W rule (75 FR 74482, November 30, 2010).
Based on this analysis, EPA concluded that subpart W will not have a significant economic impact on a substantial number of small entities. EPA made this determination assuming that all entities in the industry would report (including those above and below the reporting threshold) and determined that no significant small business economic impacts were expected to occur. This analysis showed that the cost - to-sales ratio for all entity sizes except for the smallest sized enterprises was less than 1 percent. EPA concluded that although the cost-to-sales ratio for the 1 to 20 employee range for crude petroleum and natural gas extraction was greater than 1 percent (i.e., 1.33%); in most cases, the small enterprises in this size range have very small operations (such as single family owning a few production wells) that are highly unlikely to cross the 25,000 metric tons CO2e reporting threshold. It is unlikely that any of the 99 new affected facilities that were estimated to become subject to subpart W (due to the revised GWP) would fall into the 1 to 20 employee range enterprise.
Therefore, the changes to the GWP will not have significant impact on a substantial number of small entities in Subpart W.
Subpart W (summary of impacts)
Table 5-15 summarizes the impacts of updating the GWP values in Table A-1 to subpart A, on new facilities required to report subpart W emissions.
Table 5-15. New Reporters -- Summary of Subpart W Impacts Due to the Revisions to GWPs
                          Subpart W Industry Segment
                 Number of New Reporters Due to GWP Revisions
                 Incremental CO2e Emissions for New Reporters
                        (metric tons of CO2e per year )
                   Incremental Cost Impact For New Reporters
                               (2011$ per year)

                                First Year [a]
                             Subsequent Years [a]
NG Processing
                                       2
                                    52,067
                                    62,000
                                    16,100
NG Transmission
                                       7
                                    177,091
                                    105,000
                                    44,600
Underground NG Storage
                                       6
                                    158,286
                                    122,000
                                    50,600
LNG Storage
                                       2
                                    50,000
                                    48,000
                                    16,400
LNG Import/Export
                                       0
                                       0
                                       0
                                       0
NG Distribution
                                      16
                                    400,000
                                    234,000
                                    168,000
Onshore Production
                                      52
                                   1,372,641
                                    951,000
                                    422,000
Offshore Production
                                      14
                                    362,796
                                    127,000
                                    54,700
                                     Total
                                      99
                                   2,572,881
                                   1,648,000
                                    772,000
[a] Values for total are rounded.
References for Subpart W
U.S. EPA, 2010. "Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions Under Subpart W Final Rule (GHG Reporting)". Available at: http://www.epa.gov/ghgreporting/documents/pdf/2010/Subpart-W_EIA.pdf.
U.S. EPA, 2013.  Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program.  OMB Control No. 2060-0629. EPA ICR No. 2300.10. May 2013.
Subpart HH
Subpart HH applies to Municipal Solid Waste (MSW) landfills that accepted waste on or after January 1, 1980 and generate CH4 in amounts equivalent to 25,000 metric tons of CO2e per year or more.
Subpart HH (identifying new reporters)
According to the technical supporting document (TSD) for the Landfill Sector (U.S. EPA, 2009a), 2,551 MSW landfills were estimated to be subject to subpart HH. This includes 771 active large MSW landfills, 230 active small landfills, and 1,550 closed landfills. The methods and database that were used to estimate the affected facilities for subpart HH in the TSD for the landfill sector (U.S. EPA, 2009a) can be divided into the following four categories:
Active Large MSW Landfills (771):
      The number of active large MSW landfills subject to subpart HH was identified based on the actual CH4 generation information for each active landfill in the Landfill Methane Outreach Program (LMOP) database in 2006. The CH4 generation rate in 2006 was calculated using the actual waste-in-place information and a landfill-specific model. The landfill-specific model used the first order decay model with a methane generation potential (L0) of 100 m[3]/mt and three different methane generation rate constant (k) values based on rainfall levels (U.S. EPA, 2005a).

 Active Small Landfills (230):
      It was estimated that there were 460 small active landfills in 2009 that were not covered by the 2006 LMOP database and 50% of them have CH4 generation greater than 25,000 metric tons/yr of CO2e. Fifty percent was based on engineering judgments.

 Closed Landfills (1,550):
      It was estimated that there were 6,200 closed landfills in 2009 and 25% of them have CH4 generation greater than 25,000 metric tons/yr of CO2e. Twenty-five percent was based on engineering judgments.
 Landfills that will Incur Additional Reporting Requirements in the Next Ten Years:
         * Additional subsets of both active and closed landfills will incur additional GHG reporting burden over the ten-year period following the finalization of the CH4 GWP revision (assumed to occur in calendar year 2014).
               o       Closed Landfills - It is estimated that 196 closed landfills have a current CH4 generation greater than 25,000 metric tons/yr CO2e and may be required to stay in the program longer with the revised CH4 GWP. This estimate was based on e-GGRT data for the reporting year of 2011.
               o       Active Landfills expected to close within 10 years - A similar issue will occur for landfills that are currently in operation but plan to close within the ten-year timeframe (calendar years 2015 through 2024). Based on data from the LMOP database (U.S. EPA, 2013a), it is estimated that 233 landfills will close during that ten-year timeframe that may incur an incremental reporting burden.
                     #             Of these 233 landfills, 230 either currently have CH4 generation greater than 25,000 metric tons/yr CO2e, or will have this generation rate in the scheduled closure year.
                     #             The remaining 3 landfills currently do not emit above 25,000 metric tons/yr CO2e and also would not in the scheduled closure year; however the revised CH4 GWP would result in the landfills emitting more than 25,000 metric tons/yr CO2e at some point within the ten-year timeframe.
Based on the e-GGRT data for the reporting year of 2010, there are 1,202 MSW landfills that reported under subpart HH, including 936 active landfills and 266 closed landfills. The number of the closed MSW landfills reported under subpart HH (266) is significantly lower than the original estimate of 1,550 in the TSD for the landfill sector (U.S. EPA, 2009a). However, the number of active landfills reported (936) is close to the original estimate of 1,001 (771 active large + 230 active small) landfills. Therefore, except for closed landfills, the original methods used in the TSD for the landfill sector (U.S. EPA, 2009a) to estimate the number of affected active landfills is reasonable, and the same approach is used in this analysis to estimate the number of additional MSW landfills subject to subpart HH due to the revised CH4 GWP.
Because the reporting threshold for subpart HH is based on CH4 generation (not emissions), the facilities that currently have CH4 generation between 21,000 and 25,000 metric tons/yr of CO2e are the additional facilities affected by the GWP change for CH4 from 21 to 25. Because the CH4 generation from landfills changes with time and the amount of waste in place, the time factor should be considered in this analysis. The additional active large MSW landfills, active small MSW landfills, closed landfills, and landfills that will close within the next ten years subject to subpart HH are estimated as follows:
Additional Active Large MSW Landfills:
Although the LMOP database (U.S. EPA, 2012) includes most of the input data (such as landfill open and closure years, amount of waste accepted, etc.) for the landfill-specific model used in the original analysis, this model was not re-run for this analysis. Therefore, the actual CH4 generation in 2011 for each MSW landfill covered by the LMOP database was not calculated. The best CH4 generation information available is the 2006 CH4 generation information in the supporting data for the TSD for the landfill sector (U.S. EPA, 2009a). According to this supporting data, there were 1,142 active large MSW landfills and 21 of them have CH4 generation between 21,000 and 25,000 metric tons/yr of CO2e based on 2006 LMOP database. This is equivalent to 1.8% of the total active landfills identified in LMOP database. According to the 2012 LMOP data (U.S. EPA, 2012), there are 1,123 active MSW landfills in 2012 (excluding the closed landfills). Assuming that the profile of landfills not in the LMOP database is similar to those landfills in the LMOP database, the number of active large landfills with CH4 generation between 21,000 and 25,000 metric tons/yr of CO2e is estimated to be 1,123 x 1.8% = 20 facilities.
Additional Active Small MSW Landfills:
Small landfills are not included in the LMOP database, therefore a different approach was used to estimate the additional active small landfills affected by the change in GWP. In the TSD for the landfill sector (U.S. EPA, 2009a), it was estimated that there were 460 small active landfills in 2009 and 50% of them have CH4 generation greater than 25,000 metric tons/yr of CO2e and were included in the original estimates of number of reporting facilities. Thirty percent of small landfills are estimated to have CH4 generation between 10,000 and 25,000 metric tons/yr of CO2e. Assuming that the proportion of all small active landfills is the same as those in the LMOP database, and the distribution across the available range of estimated emissions (10,000 to 25,000) is even, the number of small active landfills with CH4 generation between 21,000 and 25,000 metric tons/yr of CO2e is estimated to be 460 x 30% x (25,000  -  21,000) / (25,000  -  10,000) = 37 facilities.
Additional Closed MSW Landfills:
For closed landfills, CH4 generation and emissions decrease over time. It is estimated that the CH4 generation decreases 18% in 5 years based on the CH4 generation calculated using EPA's Landfill Gas Emissions Model (LandGEM) (U.S. EPA, 2005b). The closed MSW landfills identified in the 2006 LMOP database with CH4 generation equal to 25,000 metric tons of CO2e now should have CH4 generation around 25,000 x (1-18%) = 20,500 metric tons/yr of CO2e in 2011. With the updated GWP for CH4, the CH4 generation for these landfills is 20,500 / 21 x 25 = 24,405 metric tons/yr of CO2e, which is still less than the reporting threshold of 25,000 metric tons/yr. Therefore, the closed landfills that were identified in 2006 and with CH4 generations between 21,000 and 25,000 metric tons/yr of CO2e still would not exceed the 25,000 metric tons/year generation threshold of subpart HH after 2011 due to the revised CH4 GWP. According to the 2012 LMOP data, 92 MSW landfills were closed in the time period of 2007 through 2011 (U.S. EPA, 2012). Based on the waste in place information, none of these newly closed landfills have CH4 generation between 21,000 tons and 25,000 tons of CO2e based on a GWP for CH4 of 21. Therefore, no additional closed landfills are expected to exceed the 25,000 metric tons/year generation threshold using a GWP of 25.
Additionally, as part of the final rule requirements, EPA has revised the applicability provisions for subpart HH to exclude closed landfills that have not previously had to report under subpart HH that would be required to newly report in 2014 by exceeding the 25,000 metric tons CO2e emissions threshold for the first time solely due to the increase in the GWP of CH4. Specifically, EPA is revising 40 CFR 98.340 to add a paragraph to state: "This source category does not include MSW landfills that have not received waste on or after January 1, 2013, and that had CH4 generation, as determined using both Equation HH-5 and Equation HH-7 of this subpart, of less than 1,190 metric tons of CH4 in the 2010, 2011, 2012 and 2013 reporting years." Therefore, no additional closed landfills meeting these provisions would be required to newly report under subpart HH in 2014.
Landfills that will Incur Additional Reporting Requirements in the Next Ten Years:
Although landfill closure dates and waste-in-place information are available in the LMOP database (U.S. EPA, 2013a), e-GGRT data for the 2012 reporting year was used to identify 43 closed landfills that would incur additional reporting requirements.
For the 196 closed landfills with CH4 generation greater than 25,000 metric tons/yr CO2e, a total of 36 (18%) were identified as facilities that over the next ten years, will required to report for more years than originally anticipated. An analysis was conducted for reporters that may have additional years of reporting over the next ten years. Using the modeled generation rates for closed landfills in the subpart HH rule, a typical rate of decline in CH4 generation was calculated for closed landfills equivalent to a 3.6% reduction in CH4 generation each year and assumed that is a linear reduction (18% over five years). This value matched well with the modeled decrease in CH4 generation in the LMOP database. The annual CH4 generation reported in e-GGRT was reduced by this amount for a period of ten years, with each year being analyzed in sequence. There were a total of 36 landfills that were predicted to be subject to at least one year of additional GHG required reporting with an increase in the CH4 GWP from 21 to 25.
For active landfills that are planning to close within the next ten years, the LMOP database was selected as the source of information to use in the economic impact analysis instead of the e-GGRT 2012 reporting year data. This is because a subset of the applicable active landfills may not be currently subject to subpart HH and thus not currently required to report GHG emissions through e-GGRT. A total of four active landfills that are planned to close within the next ten years were identified as facilities that may be required to report for more years than originally anticipated over the ten year period. The LMOP database provides an annual waste acceptance rate which was used to estimate the total waste-in-place in the planned closure year. This waste amount was used to calculate CH4 generation in the closure year using Equation HH-1 from subpart HH. CH4 generation was then scaled downwards by 3.6% each year, with each year being analyzed in sequence.
The active landfills in the LMOP database were also researched for instances where the CH4 GWP of 21 would never result in the landfill emitting greater than 25,000 metric tons CO2e, but would be above this threshold within the next ten years using a CH4 GWP of 25. These represent landfills that would trigger the reporting requirements of subpart HH. These landfills would not be covered under the large or small active landfill sections described above because the increased CH4 GWP would not result in subpart HH applicability in the current year; instead, the landfill would trigger the reporting requirements of subpart HH at some point within the next ten years. An identical year-over-year analysis was conducted for the three landfills identified.
Based on the discussions above, Table 5-16 identifies the number of new subpart HH reporters that will become subject to the rule as a result of revisions to the GWPs in Table A-1.
Table 5-16. New Subpart HH Reporters by Type of MSW Landfill
                             Type of MSW Landfill
                 Number of New Reporters Due to GWP Revisions
Large Active Landfills
                                      20
Small Active Landfills
                                      37
Closed Landfills
                                       0
Landfills that will Incur Additional Reporting Requirements in the Next Ten Years
                                      43
                                     Total
                                      100
Subpart HH (estimating emissions impacts)
From Table 5-16, there would be 57 additional facilities subject to subpart HH due to the revised CH4 GWP. Emissions from these 57 additional facilities were estimated by multiplying the number of new affected facilities (57) by the average CH4 generation for each new affected facility. The average CH4 generation for each new affected facility is assumed to be (25,000 + 21,000)/2 x 25/21 = 27,381 metric tons/yr of CO2e. The amount of CO2 equivalent has been adjusted using the new GWP for CH4 of 25. Therefore, the total CH4 generation for all new affected facilities combined is equal to about 1,560,000 metric tons/yr of CO2e (57 x 27,381 = 1,560,717). Table 5-17 identifies the emissions impact from new subpart HH reporters.
          Table 5-17. Emissions Impact From New Subpart HH Reporters
                                 Facility Type
                 Incremental CO2e Emissions for New Reporters
                        (metric tons of CO2e per year )
HH  -
MSW Landfills
                                   1,560,000

Subpart HH (estimating cost impacts)
Costs were calculated by multiplying the average costs per facility and the number of new facilities estimated to be subject to subpart HH (from revising the GWPs). Average costs per facility were calculated by dividing total cost by the number of respondents identified in the most recent information collection request for the GHG reporting program (U.S. EPA, 2013).
Appendices G and L to the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to obtain first year average cost per facility that is incurred from reporting under subpart HH. Cost details from Exhibit 6.1 of the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to determine the subsequent years average cost per facility. These average costs per facility include labor costs (i.e., the cost of labor by facility staff to meet the rule's information collection requirements) and non-labor (capital, and operation and maintenance) costs. Additional details of the data, methods, and assumptions underlying these costs are documented in the most recent information collection request (U.S. EPA, 2013).
Table 5-18 shows first and subsequent year average cost per facility subject to subpart HH.

Table 5-18. Annual Average Cost Per Facility Subject to Subpart HH
                                    Subpart
                        Total Number of Respondents [a]
                                  Total Cost
                               (2011$ per year)
                               Cost Per Facility
                               (2011$ per year)

                                First Year [b]
                             Subsequent Years [a]
                                First Year [b]
                             Subsequent Years [a]
HH  -
MSW Landfills
                                     1,195
                                  10,894,000
                                   2,804,000
                                     4,300
                                     2,300
[a] This data was extracted from Exhibit 6.1 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013).
[b]  This data was extracted from the current burden & cost table in Appendix G-3 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). The one-time costs in Appendix G-3 ($2,497,000 or $2,644,000 when updated to 2011 dollars) were added to the "HH. Landfills" cost provided in Appendix G-3 ($7,736,000 or $8,046,000 updated to 2011 dollars).  The costs were updated to 2011 dollars using the Bureau of Labor Statistics Employment Cost Index and the Chemical Engineering Plant Cost Index (CEPCI). An additional $204,216 ($80.91 per respondent) was added to the total first year cost based on the current burden & cost table identified as "First Reporting Year" table of Appendix L-2 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). The $80.91 is the cost contributed to provisions of information on parent companies, NAICS codes, and whether emissions are from cogeneration. These calculations (that were used to determine the first year total cost, and cost per facility) are based on an estimated 2,524 respondents to be consistent with Appendix G-3.

By revising the GWP values in subpart A, 57 additional facilities will be required to report under subpart HH. The first year cost for these 57 facilities will be approximately $246,000 per year (57 x $4,300 = $246,000), and the annualized industry wide cost is $133,700 per year (57 x $2,346 = $133,700). An additional 43 closed or soon to-be-closed landfills will experience an incremental reporting burden over the next ten year period, due to an extended number of years reporting would be required; total additional rule implementation costs would be $373,600 for these landfills over that ten year period, or an average of $37,360 per year. This includes extended subsequent year reporting costs for 36 closed landfills, first year reporting costs for three active facilities that would be brought into Part 98 as a result of the revised GWPs, and extended subsequent year reporting costs for four active facilities that are expected to closed between 2014 and 2024, as summed over a ten-year period . A year-over-year breakdown of these costs is included in Section 5.4.5 below.
Subpart HH Small Entity Impacts (new reporters)
The small entity economic impact for landfills was measured using the "sales tests" approach (represented as cost-to-receipt ratios) for NAICS codes associated with the affected subparts in the Regulatory Impact Analysis for the GHG Reporting Rule (U.S. EPA, 2009b). The same approach is used in this analysis for the additional facilities subject to subpart HH due to the revised CH4 GWP. If the ratio of rule implementation cost to sales is less than 1%, the impact is not considered to be significant (U.S. EPA, 2010b).
Based on the 2007 economic census database published by U.S. Bureau of the Census, the receipts (sales), number of establishments, and the average receipts for different size of Waste Management and Remediation Services facilities (with a NAICS code of 562) information is summarized in Table 5-19. The average receipts information is adjusted from 2007 dollars to 2011 dollars based on the consumer price index published by Bureau of Labor Statistics.
Table 5-19. Receipts, Number of Establishments, and Average Receipts for
Waste Management and Remediation Services (NAICS code of 562)

                          Owned by Enterprises with:

                                     1-19
                                   Employees
                                20-99 Employees
                               100-249 Employees
                               250-499 Employees
                               500-999 Employees
                           1,000 and above Employees
                                   Receipts
                               (million, 2007$)
                                    $10,492
                                    $14,318
                                    $6,856
                                    $3,365
                                    $3,732
                                    $35,420
                           Number of Establishments
                                    12,579
                                     2,678
                                      646
                                      248
                                      263
                                     2,910
                    Average Receipts for Each Establishment
                               (million, 2007$)
                                     $0.83
                                     $5.35
                                    $10.61
                                    $13.57
                                    $14.19
                                    $12.17
                    Average Receipts for Each Establishment
                               (million, 2011$)
                                     $0.90
                                     $5.80
                                    $11.51
                                    $14.72
                                    $15.40
                                    $13.20

According to the cost information listed in Table 5-18, the rule implementation costs for subpart HH is $4,300 for the first year and $2,300 for the subsequent years (in 2011 dollars). The sales tests (cost-to-receipt ratios) results are shown in Table 5-20 for the first year and subsequent years.
Table 5-20. Sales Tests for Subpart HH Facilities

                          Owned by Enterprises with:

                                     1-19
                                   Employees
                                20-99 Employees
                               100-249 Employees
                               250-499 Employees
                               500-999 Employees
                           1,000 and above Employees
                                Sales Test  -
                                  First Year
                                     0.48%
                                     0.07%
                                     0.04%
                                     0.03%
                                     0.03%
                                     0.03%
                                 Sales Test -
                               Subsequent Years
                                     0.26%
                                     0.04%
                                     0.02%
                                     0.02%
                                     0.01%
                                     0.02%

The results in Table 5-20 show that the costs for GHG reporting for the facilities subject to subpart HH is well below 1% of the sales for all size of Waste Management and Remediation Services facilities with a NAICS code of 562. Therefore, it was determined that there is not a significant impact on a substantial number of small businesses subject to reporting under subpart HH as a result of this action.
Subpart HH (summary of impacts)
Table 5-21 summarizes the impacts of updating the GWP values in Table A-1 to subpart A, on new facilities required to report subpart HH emissions.
Table 5-21. New Reporters -- Summary of Subpart HH Impacts Due to the Revisions to GWPs
                                 Facility Type
                 Number of New Reporters Due to GWP Revisions
                 Incremental CO2e Emissions for New Reporters
                      (metric tons of CO2e per year ) [a]
                   Incremental Cost Impact For New Reporters
                               (2011$ per year)

                                First Year [a]
                             Subsequent Years [a]
HH  -
MSW Landfills
                                      57
                                   1,560,000
                                    246,000
                                    133,700
[a] Values rounded.

The incremental reporting burden is provided in year-over-year format in Table 5-22 for both the new reporters and the 43 existing facilities that would trigger extended reporting requirements over the following ten years. The costs for closed facilities were calculated based on applying first year and subsequent year costs to the facilities identified  (see "Landfills that will Incur Additional Reporting Requirements in the Next Ten Years", Section 5.4.1) in each year for which the facility would be subject to extended reporting requirements or would be brought into Part 98. This includes extended subsequent year reporting costs ($2,300 per facility) for 36 landfills that are or would be closed by 2014, first year reporting costs ($4,300 per facility) for three active facilities that would be brought into Part 98 as a result of the revised GWPs, and extended subsequent year reporting costs ($2,300 per facility) for four active facilities that are currently receiving waste but are expected to close between 2014 and 2024.
Table 5-22. Summary of Subpart HH Cost Impacts
                                    $/year
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2021
                                     2022
                                     2023
                                     2024
                         Landfills Closed before 2024
                                    18,800
                                    28,100
                                    30,100
                                    35,100
                                    39,800
                                    46,800
                                    44,500
                                    46,800
                                    37,400
                                    45,900
                                 New Reporters
                                    246,000
                                    133,700
                                    133,700
                                    133,700
                                    133,700
                                    133,700
                                    133,700
                                    133,700
                                    133,700
                                    133,700
                                   Total[a]
                                    264,800
                                    161,800
                                    163,800
                                    168,800
                                    173,500
                                    180,500
                                    178,200
                                    180,500
                                    171,100
                                    179,600
[a]	Total average Incremental Cost Impact for New Reporters and Reporters with Extended Reporting Requirements is $182,200 per year.
References for Subpart HH
U.S. EPA, 2005a. Development of Landfill-specific Methane Inventory Model; Memorandum from Jeff Coburn and Marvin Branscome, RTI, to Elizabeth Scheele, EPA. See Docket ID: EPA-HQ-OAR-2008-0058-0083.May 6, 2005.
U.S. EPA, 2005b. Landfill Gas Emissions Model (LandGEM), , Version 3.02. [Computer software]. Retrieved July 12, 2012. Available from http://www.epa.gov/ttn/catc/products.html#software
U.S. EPA, 2009a. Technical Support Document for the Landfill Sector: Proposed Rule for Mandatory Reporting Of Greenhouse Gases. See Docket ID: EPA-HQ-OAR-2008-0508-0034. February 4, 2009.
U.S. EPA, 2009b. Regulatory Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions Final Rule (GHG Reporting). See Docket ID: EPA-HQ-OAR-2008-0508-2229. September 2009.
U.S. EPA, 2012. Landfill Methane Outreach Program (LMOP)  -  Landfill and Project Database. January 4, 2012. Available from: http://www.epa.gov/lmop/documents/xls/lmopdata.xls
U.S. EPA, 2013a. Landfill Methane Outreach Program (LMOP)  -  Landfill and Project Database. June 13, 2013. Available from: http://www.epa.gov/lmop/documents/xls/lmopdata.xls
U.S. EPA, 2013b.  Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program.  OMB Control No. 2060-0629. EPA ICR No. 2300.10. May 2013.
Subpart II
The industrial wastewater treatment source category consists of anaerobic processes used to treat industrial wastewater and industrial wastewater treatment sludge at facilities that perform the following operations: petroleum refining; pulp and paper manufacturing facilities; ethanol production; and food processing.
Facilities that meet reporting thresholds must report the amount of CH4 generated, emitted, and/or recovered from anaerobic treatment of industrial wastewaters and industrial wastewater treatment sludges. Subpart II applies only to anaerobic treatment processes.
For the industries covered by subpart II, the reporting thresholds are specified as follows:
Petroleum refineries are required to report if the facility is subject to reporting under subpart Y of 40 CFR part 98. There is no threshold for reporting.
Pulp and paper manufacturing facilities are required to report if the facility emits 25,000 metric tons CO2e or more per year. All pulp and paper facilities are expected to meet this threshold.
Ethanol production facilities are required to report if the facility emits 25,000 metric tons CO2e or more per year.
Food processing facilities are required to report if the facility emits 25,000 metric tons CO2e or more per year.
Subpart II (identifying new reporters)
This section discusses how EPA estimated the number of facilities required to report during the development of the Greenhouse Gas Reporting Rule. It then discusses how these estimates would change if the methane GWP increased from 21 to 25. The discussion is presented separately for each of the four industries included in subpart II.
Petroleum refineries. During the development of the GHG reporting rule, EPA noted that 40 CFR 98.2(a)(1) requires all 150 petroleum refineries to report their GHG emissions. As part of the estimate of the potential costs of subpart II, EPA further estimated that 25% of refineries have anaerobic wastewater treatment and would be required to report subpart II emissions (ERG, 2010). However, in the 2011 reporting year, there were no facilities identified that reported both petroleum refining emissions and subpart II emissions. For these reasons, any change to the methane GWP will have no impact on the estimated number of petroleum refineries required to report subpart II emissions.
Pulp and paper manufacturing facilities. During the development of the GHG reporting rule, as part of the estimate of the potential costs of subpart II, EPA estimated that 25% of the 565 U.S. pulp and paper mills have anaerobic treatment. EPA further assumed that all 141 mills with anaerobic secondary treatment would meet the 25,000 metric tons CO2e threshold of emissions from their subpart AA operations and would be required to report subpart II emissions (ERG, 2010). In the 2011 reporting year, there were 7 facilities that reported both pulp and paper manufacturing emissions and subpart II emissions. Because mills are assumed to meet the reporting threshold based on their subpart AA CO2 emissions, any change to the methane GWP will have no impact on the estimated number of pulp and paper mills required to report subpart II emissions.
Ethanol production facilities. Ethanol production facilities are required to report their GHG emissions if they exceed 25,000 metric tons CO2e per year in combined emissions from all specified sources, such as stationary fuel combustion units, industrial landfills, and industrial wastewater treatment. However, for the purpose of its March 2010 cost estimate, because EPA had no basis for estimating emissions from other sources at the ethanol production facility, EPA assumed facilities that exceed 25,000 metric tons CO2e per year in emissions from industrial wastewater treatment would incur monitoring costs (ERG, 2010).
Facilities use one of two processes to produce ethanol: dry milling or wet milling. During the development of the GHG reporting rule, EPA obtained information from the Renewable Fuels Association that included facility identification, production, and whether the facility used dry milling or wet milling. This information did not identify facilities that use anaerobic wastewater treatment. Assuming each facility used anaerobic treatment and using standard waste generation rates based on ethanol production, chemical oxygen demand (COD) concentrations, and methane generation rates, EPA calculated potential methane emissions per plant.
Dry milling. The maximum estimated emissions from a facility were slightly over 1,800 metric tons CO2 e per year. Even if the methane GWP were increased by 20%, no dry milling ethanol plant would meet the 25,000 metric tons CO2 e per year reporting threshold.
Wet milling. Wet milling ethanol production facilities generate more wastewater per unit of production and have somewhat greater production per facility than dry milling facilities. Four wet milling facilities produce 1.5 to 2.5 times as much ethanol as the largest dry milling facility. Because EPA had very little information on how individual ethanol production facilities treat wastewater, in order to estimate the potential costs of subpart II, EPA estimated that 33% of the wet milling facilities used anaerobic wastewater treatment. Using standard waste generation rates based on ethanol production, COD concentrations, and methane generation rates, EPA calculated that four (4) wet milling facilities emitted in excess of the 25,000 metric tons CO2 e per year reporting threshold. EPA estimated that ethanol production facilities would incur $20,600 in total annualized costs to meet the GHG reporting rule monitoring requirements (ERG, 2010), or $5,150 per facility.
In a more recent analysis, EPA estimated that two wet milling ethanol production facilities exceeded the reporting threshold. Changing the GWP to 25 would increase this estimate by two, to a total of four facilities. In the 2011 reporting year, there were 17 ethanol production facilities that reported subpart II emissions. However, the subpart II emissions for each of these facilities were under the 25,000 tons per year threshold; the facilities exceeded the threshold based on subpart C combustion emissions. Using these sources of information, it is estimated that the impact of a change to the GWP for methane from 21 to 25 will result in two additional facilities that will be required to report.
Food processing facilities. Food processing facilities are required to report their wastewater emissions if Facility GHG emissions exceed 25,000 metric tons CO2e per year in combined emissions from all specified sources, such as stationary fuel combustion units, industrial landfills, and industrial wastewater treatment. However, for the original development of the rule, because EPA had no basis for estimating emissions from other sources at the food processing facility, EPA assumed facilities that exceed 25,000 metric tons CO2e per year in emissions from anaerobic industrial wastewater treatment alone would be subject to the rule (ERG, 2010). Food processing facilities that are most likely to have anaerobic wastewater treatment are: 1) fruits and vegetable processing, 2) poultry processing, and 3) red meat processing.
Fruits and vegetable processing. During the development of the GHG reporting rule, as part of the estimate of the potential costs of subpart II, EPA estimated that no fruit and vegetable processing facilities would incur reporting costs because all would be under the reporting threshold (ERG, 2010). As discussed in the July 2008 threshold analysis (ERG, 2008b), EPA could not identify plant-specific information to calculate greenhouse gas emissions for fruit and vegetable processors. The national level of emissions from the 2006 U.S. Inventory of U.S. Greenhouse Gas Emissions and Sinks is 123,000 metric tons CO2e. There are approximately 100 processors with onsite anaerobic treatment (U.S. EPA, 2008); therefore, the average emission was estimated to be about 1,200 metric tons CO2e per plant (ERG, 2008b). If the methane GWP increased from 21 to 25, the average emission would increase to about 1,460 metric tons CO2e per plant, still significantly below the 25,000 metric tons CO2e reporting threshold. Thus, an increase in the methane GWP would have no effect on the number of fruit and vegetable processing facilities required to report subpart II emissions.
Poultry processing. During the development of the GHG reporting rule, as part of the estimate of the potential costs of subpart II, EPA determined it did not have sufficient information to estimate the number of poultry processing facilities that exceed the 25,000 metric ton CO2e reporting threshold. EPA estimated 50 poultry processors have methane emissions above 10,000 metric tons CO2e (ERG, 2010). This is an overestimate of those that have emissions above 25,000 metric tons CO2e, but EPA does not have sufficient facility-specific information to refine the estimate, nor to estimate the impact of changing the methane GWP.