Kong Chiu

U.S. Environmental Protection Agency

Case Study:

U.S. Greenhouse Gas Reporting Program,

Collecting, Verifying and Publishing Enterprise-Level GHG Data

World Bank Partnership for Market Readiness (PMR)

Data Management Workshop

October 21st, 2012

Sydney

Overview

• Introduction to US GHGRP

• National Inventory vs. Facility Reporting

• Regulatory Process

• Programmatic Requirements

• Data Collection and Management

• RY2010 Data Results

• Costs

Introduction to US GHG Reporting Program

• Annual mandatory reporting of GHG by:

– Rule covers 41 source categories for reporting, accounting for 85-90% of total U.S. GHG emissions:

– 33 types of direct emitters

– 6 types of suppliers of fuel and industrial GHG

– Facilities that inject CO2 underground for geologic sequestration, enhanced oil recovery, or any other purpose.

• Direct reporting to EPA electronically

• EPA verification of emissions data

• Monitoring began in 2010 for most emission sources with first reports submitted to EPA in September, 2011

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GHG Inventory, GHG Reporting Program

• The U.S. GHG Inventory is a comprehensive top-down assessment of national GHG emissions and removals which presents emissions across multiple years starting in 1990.

– U.S. GHG emissions calculated using internationally-accepted methods and nationally appropriate statistics

– Emissions estimates not provided at the geographic or facility level – Includes small industrial emitters, residential and commercial sectors – Includes agriculture and land-use/forestry sectors

• When compared in aggregate, some of the summary emissions totals for

specific industries appear different in the Inventory and GHGRP. – Different Source Category Definitions – Reporting Threshold – Lack of Disaggregated Data to Represent Certain Industries – Use of Continuous Emissions Monitoring Technologies – Differences in use of Default International Factors from Facility-Specific Methods

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Regulatory Process

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Regulatory Process

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Clean Air Act (1963, 1970, 1977, 1990)

Administrative Procedures

Act

US Congress Passes

US President Signs

US EPA Develops

Regulations

Greenhouse Gas Reporting

Rule

Regulatory Timeline, Stakeholder Outreach

• 26 December, 2007: Appropriations Act

• January, 2008: Rule Development

• 10 April, 2009: Proposed Rule

• 10 April – 9 June, 2009: Notice & Comment Period

• 6 April and 16 April, 2009: Public Hearings

• 30 October, 2009: Final Rule

• 1 January, 2010: First reporting year begins

• 30 September, 2011: First data collected

Stakeholder Engagement

Programmatic Requirements

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Programmatic Requirements

• All-In Category: Any source category listed under Table A-3 of rule, including: Adipic Acid, Aluminum, Cement, Lime, EGUs (Part 75), Petroleum

Refineries etc… • Threshold Category: Any facility that emits 25,000 metric tons CO2e or more per year from: All applicable source categories (Table A-4) at single facility (i.e

Ferroalloy production, Glass production, Iron & Steel etc…) Stationary fuel combustion units Miscellaneous use of carbonates • Suppliers: Any supplier listed under A-5, including: Petroleum products, Coal-

Based Liquids, Industrial GHGs

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All-In Sources

10 * Manure Management Systems (Subpart JJ): EPA will not be implementing subpart JJ due to a Congressional restriction prohibiting the expenditure of funds for this purpose.

Threshold Sources

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Over 6,000 Reporters in RY2010

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0 200 400 600 800 1000 1200 1400 1600 1800

·         Lime Manufacturing

·         Other Minerals

·         Cement Production

·         Glass Production

Refineries

Ethanol Production

Manufacturing

Government and Commercial

Other Industrial

Pulp and Paper

Metals

Food Processing

Chemicals

Oil and Natural Gas

Landfills

Power Plants

RY2010 GHGRP Number of Reporters (Direct Emitters)

Methodologies

• Methodologies developed from extensive review of existing GHG programs

• Tiering approach used in many sub parts (lower order to higher order)

• Example: Stationary Combustion employs 4 Tier Approach

• In addition to calculation methodologies, the GHG Rule Requires: – Adherence to and reference of Standards (ASTM, ISO etc…) – Calibration requirements – Missing data procedures – Extensive recordkeeping requirements

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Electronic Data Collection and Management

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Electronic Data Collection: Key Components

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GHG Report

Submission and

Re-Submission

USER

Registration

FACILITY

Registration

And

Roles

Real-Time Data

Validation

USER

Authentication

GHG Data

Entry/Upload and

Calculation

Support

CROMERR

Electronic

Signature

Master

Data Store

(Database)

Secure

Facility <-> EPA

Communication

Data Collection: e-GGRT

• EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT)

• Web-based application for facilities/suppliers to report directly to EPA

• For Reporting Year 2010, included 29 individual sub-part modules, each with self-guided web forms

• Additional 12 Source Category modules added in mid-2012

• Also includes option for direct data upload via XML

• Annual Reports are electronically submitted and CROMERR Compliant

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Electronic Reporting Tool

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Interactive Tax software-like

Interview workflow

Electronic Reporting Tool (cont’d)

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Tab Navigation

Context-Sensitive

Help

Part 98 Rule Equations

Rolling “tax refund”

style GHG Calculator

Real-time

Data Quality Feedback

Electronic Data Management

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Reporters Appox. 10,000

Facilities and

Suppliers

e-GGRT, interactive web-based,

CROMERR compliant data reporting

tool, 40+ modules

e-GGRT Database

Servers (Master Data Store)

Data Verification

(EPA)

Collection (e-GGRT XML Reporting Schema)

e-GGRT

Datamart GHGRP Data

Publication Website (ghgdata.epa.gov)

GUI with open-source APIs. .

Publication (Datamart XML Schema)

Downloadable XLS,

XML & HTML Data Files,

all non-CBI data (e-GGRT XML

Reporting Schema). Open Access to

Public

State-Specific Service Oriented data flow over

State-EPA Exchange Network

(e-GGRT XML Reporting Schema)

EPA EnviroFacts: (Under

Development)

Serviceable, searchable and separately

hosted copy of non-CBI dataset. Open

Access to Public

EPA GHG Data System

CBI

Redaction

California GHG Reporting

Emissions Data

Product Data

Allowance Allocations

Data Verification

• Reporter Self-Certifies

• Electronic Verification – Pre-submittal warning for reporters entering data outside

reasonable ranges or missing data

– Post-submittal verification through logic checks, use of outside data sets, and statistical analyses across facilities

– Improvements to ranges & algorithms over time with real data

• Staff review and direct follow-up – Staff review electronic verification results

– Phone/email follow-up- built in secure communications via e-GGRT

• Resubmissions, as needed

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Verification Checks (examples)

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Type of Check Example

Validation

The annual CH4 emissions for the subpart have not been reported Max. rated HI capacity was not reported for the subpart

Range Group max. rated heat input (HI) cannot exceed 250 mmBtu/hr Unit operating hours cannot exceed 8,784

Algorithm Fuel is not appropriate for a unit using a Tier 1 method with a maximum rated HI capacity greater than 250 mmBtu/hr The annual CO2 emissions is more than expected based on fuel type and max. rated HI capacity

Statistical The ratio of annual CO2 emissions to max. rated HI has been identified as a potential outlier for large-capacity units that burn oil/gas.

RY2010 Data Highlights

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Data Publication

• Multi-Prong Approach

– Interactive Data Publication Website (ghgdata.epa.gov) – Downloadable Data Files – Service-oriented application programming interface (APIs)

• Increase understanding of the sources of GHG emissions in the U.S. among the public

• Voluntary management

• Improve quality of reported data

• Support regional, state, and local programs

• Provide a tool for schools, students, researchers and journalists

• Information displayed in a simple, transparent manner

• Allows public to use data in creative ways 24

RY2010 GHG Data

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Power Plants

Refineries

All Other

RY2010 Data: National Map

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Costs

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Costs (Reporters)

• Regulatory Impact Analysis (RIA) – Estimates cost and benefits of regulatory action

• Information Collection Request (ICR) – Estimates burden associated with information collection

• Estimated Costs of Compliance (RIA and ICR) – Annualized Costs, including

• Applicability determination • Monitoring, recordkeeping, reporting activities • Labor costs • Capital and O&M Costs

– Original RIA (2009) – ICR Renewal, Proposed Collection (May, 2012) – For more information:

• http://www.epa.gov/ghgreporting/documents/pdf/archived/GHG_RIA.pdf • http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2012-

0333-0001 28

Costs (EPA)

• Agency Costs

– Oversight and implementation of program

– Collection, verification and publication of emission reports

– Database and software maintenance

– Communication & Outreach including Help Desk support

– EPA Staff and subject matter experts

– Consultants and technical experts

• FY2012 Agency Budget (enacted)

High Quality Data begins with High Quality Submissions

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• Real Time Data Quality Feedback

• Comprehensive GHGRP Help Site

• www.ccdsupport.com

• Context-Sensitive Help within e-GGRT

• Staffed Help Desk

• Multi-Tier Ticket Triage

• Received and resolved over 3,000 tickets during RY2010 Reporting Season

• Training Webinars

• Part 98 overviews, e-GGRT overviews, registration, testing and subpart webinars

• Beta Testing

• e-GGRT Sandbox

For More Information

• Part 98 (Mandatory Reporting Rule) Info: – www.epa.gov/ghgreporting

• Electronic Reporting, General GHGRP Help: – www.ccdsupport.com

• Published Data: – ghgdata.epa.gov

– Kong Chiu – US EPA – 1200 Pennsylvania Ave NW – Washington, DC 20460 USA – 1+202-343-9309 – chiu.kong@epa.gov