Cal e-GGRT Help

Q254. Our operation includes a supplier under one subpart and a facility under another. Do they have to have the same Designated Representative (DR)?

Note: The Cal e-GGRT help system includes general instruction on using the California GHG reporting tool. However, the help system may not explain differences between California and U.S. EPA reporting requirements. Please refer to the ARB reporting website for California-specific reporting requirements and additional help.

Created by Theresa Mastrian, last modified by Peter Kobylarek on Jan 31, 2012

No. Rule language permits you to name a separate DR for a supplier even if the operation happens to be co-located with a facility. According to Part 98.4(a) each "facility, and each supplier, that is subject to this part, shall have one and only one designated representative, who shall be responsible for certifying, signing, and submitting GHG emissions reports and any other submissions for such facility and supplier respectively to the Administrator under this part." The rule distinguishes between facility subparts (C through JJ) and supplier subparts (KK to PP). The purpose here is to allow the reporter the option to name a different DR for a facility subpart and a supplier subpart even if they are at the same company or location.