Q830. Will the change to the missing data provisions in Subpart A of the December 9, 2016 rule greatly increase reporting burden?

A830. No, the final revisions in the December 9, 2016 rule will not greatly increase reporter burden.  EPA has found that this revision affects only two parameters in 40 CFR 98.  Specifically, facilities that report under Subpart O – HCFC-22 Production and HFC-23 Destruction (40 CFR 98.155) can, as the result of this revision, be required to report the duration for which missing data procedures were used to estimate (1) the chemical concentration in a product and (2) the mass of that product.  The “Procedures for estimating missing data” section of Subpart O already specified missing data calculations for these two parameters, so the only increase in burden is that facilities using these provisions must now report the duration of the use of these provisions for these two parameters.

The revision changes the term ”data element” in Section 98.3(c)(8) to the term “parameter” because the two parameters noted above do not clearly qualify as “data elements” since they are not individually reported.  This revision harmonizes the language of the GHGRP general provisions with language used in individual subparts of the GHGRP.  EPA has not to date identified any other parameters affected by this revision.