Q703. What must I do if EPA notifies me of a potential substantive error in an annual GHG report?

A703. If EPA notifies you of a potential error, then you have 45 days to either: (1) submit a revised GHG report that corrects the error, or (2) provide information to EPA that demonstrates that the report does not contain an error or that the error is not a substantive error. A substantive error is an error that impacts the quantity of GHG emissions reported or that prevents the data from being validated or verified.

Under the rule, you are responsible for resolving the substantive error within the allowed 45 days. The 45 days includes the time needed to analyze the potential error, complete communications with EPA on any issues, and submit the final resolution to EPA. If you cannot reasonably resolve the substantive error within 45 days of the initial notification from EPA, then you should request a 30-day extension prior to the expiration of the 45-day period through the facility's EPA Correspondence Folder in e-GGRT. For information on using the EPA Correspondence Folder, see http://www.ccdsupport.com/confluence/display/help/Correspondence+Tracking. An extension is required for any case were the 45 day window will expire and the issue is not yet resolved / closed, even if you are in the process of communicating with EPA and are awaiting a response from EPA on any question or issue. See 40 CFR 98.3(h) for more information.