Q708. If I am a refinery or coal-to-liquid facility required to report under subpart MM or LL and also report direct emissions under another Part 98 subpart, do I need one e-GGRT registered entity or two? Which subparts do I include in each report?

In order to complete one registration for both direct emitter and supplier source categories, a single designated representative for both sets of operations must complete the Certificate of Representation submission process in e-GGRT. Additional information on using e-GGRT to complete facility registration can be found here: http://www.ccdsupport.com/confluence/display/help/About+Facility+RegistrationA708. If both the direct emitter (source categories in Tables A-3 or A-4) and supplier (source categories in Table A-5) operations have the same designated representative and are in the same physical location, you may be able, but are not required, to register once in e-GGRT for both the direct emitter and supply operations. Further, you may be able, but are not required, to submit one annual GHG report containing information for both your direct emitter and supplier operations. Because they report at the corporate level rather than at the facility level, importers and exporters must register and report separately.

One Certificate of Representation would be submitted that applies to both the direct-emitter and supply operations (see 98.3(c)(9)). Further, in order to submit one Certificate of Representation, and subsequently one annual GHG report (covering both direct-emitter and supply operations), the general information reported in 98.3(c) must be the same for both your direct emitter and supply operations. If these criteria are met, you may register your entity once in e-GGRT and submit one annual GHG report including both your direct emitter and supply operations.

If the direct emitter and supplier have different designated representatives, or if you will report different information under 98.3 (c) for the direct emitter and supply operations, then you must register and report for your direct emitter and supply operations separately.

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Source: Brian Cook, 12/6/2012 (MM FAQs 12 5.docx)

Approval / Publishing History: Version 1

Expiration: none

Relevant Subparts:  Subpart MM and Subpart LL

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