Q346. Is a paper making company required to report GHG emissions under Subpart AA if the only source of emissions is on -site combustion?

A346. No. Subpart AA only requires data reporting for chemical recovery furnaces at kraft and soda mills, chemical recovery combustion units at sulfite facilities, chemical recovery combustion units at stand-alone semichemical facilities, pulp mill lime kilns at kraft and soda facilities, and systems for adding makeup chemicals (CaCO3, Na2CO3) in the chemical recovery areas of chemical pulp mills. If the only source of emissions at a paper mill is on-site combustion (in a boiler, for example), reporting under subpart AA would not be required. Reporting under subpart C might be required if the facility emits 25,000 metric tons CO2e (excluding biogenic CO2) or more per year in combined emissions from all stationary combustion sources.