Q285. I am required to report as both a facility and a supplier under Part 98? How will e-GGRT handle registration and reporting for my facility?
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.

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.

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+Registration

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.

Please note that reporters subject to Subpart LL (Suppliers of Coal-based Liquid Fuels) and/or Subpart MM (Supplier of Petroleum Products) must use the OTAQREG system to register and report for those operations. E-GGRT will not support Subpart LL or MM reporting. If your facility or supplier is required to report under any other subpart in addition to LL or MM, (for example, stationary combustion), then you will have to register in e-GGRT and submit a separate Certificate of Representation and annual GHG report for those other subparts under e-GGRT.

This web site is maintained by a contractor to the California Air Resources Board (RY2015.R.03)