{longname}  Q50. When are reporters required to complete their GHG Monitoring Plan?
{longname}

A50. ThePart EPA98 requires that theall Monitoringreporters Plan will be developed by no later than April 1, 2010, which issubject to the daterule whenhave the fulla monitoring approachplan will be implemented by most sourcesin place. The purpose of the plan is to document the process and procedures for collecting and reviewing the data needed to estimate annual GHG emissions. Therefore, this plan needs to be in place prior to collecting data to ensure that consistent and accurate data are collected. 

Additionally, Thethe EPAmonitoring estimatesplan thatmust 3include monthsall isof athe reasonableelements timelisted forin a40 source to develop this plan since, as explained in the preamble to the final rule, the plan does not have to be complex and can rely on existing corporate documents like SOPs and Monitoring Plans developed for compliance with other air programs. While some facilities may use best available methods to estimate GHG emissions for a period beyond 3 months (after April 1, 2010), facilities still need to have a plan developed for the basic procedures that will be used to collect data. A facility's data collection methods may change and evolve as the facility gains experience with monitoring equipment and develops more effective procedures for data management. Under the final rule, the Monitoring Plan must be revised to reflect these changes.
CFR 98.3(g)(5)\(i) of the rule. Per 98.3(g)(5) GHGRP reporters are required to maintain monitoring plans, but are not required to submit them using e-GGRT. Monitoring Plans are a record keeping requirement, not a reporting requirement. 

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Source: This question and answer was derived from a Legacy FAQ, revisions provided by B. Master, 2/12/2013

Approval / Publishing History: Version 12

Expiration : none

Relevant Subparts:  Subpart A
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