Greenhouse Gas Reporting FAQs

Created by Nvart Boyajian, last modified by Marty Huppert on Dec 09, 2011

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FAQID	Subpart	Description
Q1	A	What is the action being taken?
Q2	A	What is the purpose of the rule?
Q3	A	What is the effective date of the rule?
Q5	A	Who will have to report under the final rule?
Q7	A	Which greenhouse gases (GHGs) are covered under the rule?
Q9	A	Are mobile sources included in this rule?
Q10	A	What is the definition of a "facility"?
Q11	A	Will EPA collect data at the unit-, facility-, or corporate-wide level?
Q12	A	Will EPA accept emissions information from facilities that do not have to report under the mandatory reporting rule? Basically can reporters provide voluntary information to EPA following MRR protocols? In turn would EPA keep this info and share it with the states?
Q13	A	Can you please describe what constitutes a facility? For example, if a hospital has four buildings, does the rulemaking pertain to the four buildings as a composite, or to each individually? What if the four separate buildings are connected by above-ground or below-ground walkways/tunnels? What if an industrial campus has several different businesses on its property? Each business calculates their own? And if one of the businesses has several buildings, are they treated as a composite or individually? Additionally, the same would apply for a University that has buildings on one campus, or as in many urban settings, the buildings are located in various addresses in a city.
Q14	A	What is the estimated cost to implement this rule?
Q15	A	What impact does this rule have on small businesses?
Q16	A	Did EPA engage stakeholders in the development of the rule?
Q17	A	Was my comment submitted during the public comment period addressed?
Q18	A	Is this rule a cap and trade regulation?
Q19	JJ	How does the restriction attached to EPA's Appropriation Bill for 2010 impact Subpart JJ (Manure Management Systems) in the final Mandatory Reporting of Greenhouse Gases Rule that was published in the Federal Register on October 30, 2009?
Q20	A	Does the rule apply to U.S. Territories?
Q21	A	How did EPA develop the general threshold of 25,000 metric tons of carbon dioxide equivalent (mtCO2e) per year?
Q22	A	How much is 25,000 metric tons of CO2 equivalent (mtCO2e)?
Q23	A	Are there some sectors where all facilities have to report regardless of whether they meet the 25,000 metric tons of carbon dioxide equivalent (mtCO2e) annual threshold?
Q25	A	Will all direct emitters of greenhouse gases (GHGs) be included in the rule?
Q26	A	Is there a simple way for facilities with stationary fuel combustion units to determine if they will be required to report?
Q27	A	Will individual home owners be required to report under this rule?
Q28	A	Will individual car or truck owners be required to report?
Q29	A	Will owners of commercial buildings be required to report?
Q30	A	Will federal, state, or local facilities have to report emissions?
Q31	A	Are terrestrial carbon sequestration ("sinks") and offsets projects included in this rule?
Q32	A	Why are both downstream and upstream reporting required?
Q33	A	Will there be double-reporting of emissions under this rule?
Q35	A	How is the reporting of ethanol production and or biogenic emissions being handled in the rule?
Q36	A	The Applicability Tool says I need to report, but I don't think the tool is right. Please confirm.
Q37	A	Is applicability based on actual emissions or potential emissions?
Q42	A	How will emissions data be verified?
Q43	A	Will EPA provide training and guidance for reporters?
Q44	C	There are currently no CEMS available at my facility. Is there a provision to allow calculations of Tier 1, 2 or 3 if the cost of purchasing and installing CEMS will be seriously detrimental to the company?
Q45	A	If facility intends to obtain fuel usage data from utility bills, but its utility bills reflect fuel usage through middle of the month, how does EPA recommend a facility estimate fuel use for the calendar year? Is it acceptable to pro-rate fuel use?
Q50	A	When are reporters required to complete their GHG Monitoring Plan?
Q51	A	What representative of a reporting facility is in charge of reporting? For example, is it the operator or facility owner? What if a contractor operates a facility owned by someone else? Lastly, can a third partybe hired to report on behalf of the reporting facility?
Q53	A	Does this final rule preempt states from regulating or requiring reporting of greenhouse gases (GHGs)?
Q54	A	Will data collection be delegated to state agencies?
Q56	A	How is this reporting rule different from the Inventory of U.S. Greenhouse Gas Emissions and Sinks report (Inventory)?
Q57	A	Will this rule negate the need for the Inventory of U.S. Greenhouse Gas Emissions and Sinks in the future?
Q58	A	Would this rule need to be addressed in Title V operating permits?
Q59	A	How could the passing of the Waxman-Markey Bill affect this regulation?
Q60	A	How will the GHG Reporting Rule fit in or be harmonized with state and local reporting obligations for criteria pollutants, toxics, and state-specific GHG reporting requirements?
Q61	A	How will data be efficiently shared among existing state greenhouse gas (GHG) programs and this new federal reporting program?
Q62	A	Where can I find more detailed information on the rule?
Q64	C	Should pilot gas be included in greenhouse gas calculations?
Q66	C	Where does no. 2 diesel fuel fit into Table C-1 and C-2?
Q67	C	Where the heat input capacity of a combustion unit is less than 250 mm Btu per hour input capacity and the unit is not subject to Tier 3 or 4 per Subpart Y of Part 98, and where there might be more than one fuel type fed to...?
Q68	C	40 CFR §98.33(a)(3)(iii) indicates that "For units that combust municipal solid waste (MSW) and that produce steam, use Equation C-2c of this section". However, Table C-1...
Q70	C	Would fuels combusted in a test stand be considered as stationary fuel combustion when the articles being tested are mobile sources (aircraft, rocket, missile, spacecraft)?
Q71	C	For CAIR-affected units that monitor SO2 and NOX emissions and Heat Input using the provisions of Part 75 Appendix D & E, but are not required to report CO2 mass emissions, may Part 75 Appendix G be used for CO2 reporting under Part 98?
Q72	C	For a unit that currently uses gas monitors for other pollutants, but does not have a flow monitor, is it necessary to install and certify a flow monitor by March 31, 2010...?
Q73	C	If a non-Acid Rain unit combusts coal or other solid fossil fuel and has gas monitors installed but does not have a stack flow monitor, is installation and certification of a stack flow monitor required?
Q74	C	If a unit that combusts only fossil fuels has a CEMS for CO2 and uses Tier 4, must CO2 be reported by fuel type?
Q75	C	For a unit that combusts fossil and biomass fuels that has a CEMS for CO2 and uses Tier 4, must CO2 be reported by fuel type?
Q76	C	For a group of units that combusts only pipeline quality natural gas, may a shared fuel flow meter on a common pipe or gas supplier billing meter data be used to determine the CO2 mass emissions for the group of units?
Q77	C	For a unit that has an O2 monitor and doesn't meet the conditions required to use Tier 4, but elects to use Tier 4, what are the monitoring requirements?
Q78	C	For a source that has CEMS for other pollutants, but not for CO2 mass measurement, and is required to use Tier 4, when must the monitors be installed and certified?
Q80	C	If the HHV is known as part of a general energy management system, but not sampled on a routine basis, may Tier 1 be used?
Q82	C	For a non-Acid Rain combustion turbine rated over 250 mmBtu per hour that only burns diesel oil and pipeline natural gas, is it acceptable to use Tier 2...
Q83	C	For diesel fuel (e.g., No. 1 or No. 2 fuel oil) shipments that are received 1 or 2 times a year, is it sufficient to sample the fuel carbon content upon receipt of each shipment for Tier 3?
Q84	C	For a unit that is not required to use Tier 4 (CEMS monitoring), which tier is required if you receive HHV with some coal shipments, but not every coal shipment?
Q85	C	Is the use of Subpart C tiers required after 2010 and is it acceptable to use the best available monitoring provisions under Subpart A beyond 2010?
Q86	C	Does Tier 3 have to be used if a unit is less than or equal to 250 mmBtu per hour, but has a continuous gas chromatograph to determine carbon content?
Q87	C	What Tier, if any, must be used for a fuel not listed in Table C-1 that is less than 10% of the heat input of a combustion unit?
Q88	C	If a combustion unit with a heat input capacity less than 250 mmBtu per hour burns both natural gas and a liquid fuel, and the quantities are known...
Q89	C	Do facilities that are required to use the Tier 4 calculation methodology in subpart C have to apply for an extension under 98.3(d)(2) if they cannot get the appropriate equipment in place by March 31, 2010?
Q90	C	Does EPA accept thermal flow meters for measuring volumetric flow rate under 98.34?
Q91	C	Are orifice, venturi, and nozzle flow meters required to have temperature, and total pressure transmitters located on the flowmeters?
Q92	C	For a unit that operates continuously with infrequent outages and will not be able to meet the April 1, 2010 deadline for the initial calibration of a Tier 3 fuel flow meter, does the facility have to request an extension from EPA?
Q93	C	What should facilities do if the calibration error for fuel flow meters that exceeds the 5.0% performance specification?
Q94	C	For Tier 3, if the equipment in place on January 1, 2010 is unable to measure carbon content and molecular weight of the fuel on a daily basis, must that equipment be replaced?
Q95	C	If a facility has a billing meter for natural gas distributed to the combustion units throughout the facility, and if these combustion units also have their own meters, is there an obligation...
Q98	HH	The landfill industry uses a portable meter that uses an IR method to determine methane and carbon dioxide concentrations. Has the EPA determined if these units are acceptable and comply with the accuracy required by the rule?The landfill industry uses a portable meter that uses an IR method to determine methane and carbon dioxide concentrations. Has the EPA determined if these units are acceptable and comply with the accuracy required by the rule?
Q100	HH	When does moisture content need to be corrected for in Equation HH-4?
Q102	HH	What models are acceptable for performing the calculations in subpart HH?
Q103	HH	How should inert wastes be accounted for in Equation HH-1?
Q104	HH	The methods listed in section 98.344 are not applicable to my monitor, how should I calibrate?
Q105	HH	What is the definition of facility as it relates to landfills and landfill gas to electric (LFGTE) plants?
Q106	HH	We do not have any records or receipts for the waste quantities that were placed in our landfill before 2000, how do we estimate historic waste quantities before that year?
Q107	HH	If an MSW landfill has a dedicated area which receives waste other than MSW, may this area be excluded from the rule requirements?
Q108	HH	If an MSW landfill is later remediated as a hazardous waste landfill, does it need to comply with the rule?
Q109	HH	If I use a flame ionization detector (FID) or an infrared (IR) monitor, am I required to determine an annual non-methane organic correction factor?
Q110	A	If two entities share a Title V permit would that preclude them from reporting separately even if there is no common ownership or control?
Q111	HH	Do landfills have to report the biogenic CO2 that is included in LFG emissions and the CO2 that is emitted from flares?
Q112	HH	How does EPA define "at least weekly" in the monitoring requirements?
Q113	HH	If all of our landfill gas gets piped offsite to another facility, what do we need to report?
Q114	HH	Can an alternate oxidation factor, other than 10% be used in the calculations?
Q116	HH	Do passive flares count as "gas collection systems" under the provision below? Do the landfills with these systems have to collect data weekly?
Q117	HH	Does EPA's definition of treatment equipment include moisture knockout and blower systems? Is it acceptable to EPA for the flow meter to be placed after the moisture knockout and blower or is it required to be placed before these items?
Q119	HH	Are annubars or v-cone flowmeters acceptable for compliance with the rule requirements?
Q120	HH	Is weekly monitoring of both gas flow and methane concentration allowed?
Q121	HH	The applicability tool refers to a 350,000 waste-in-place threshold. Is reporting required if the total waste-in-place is less than 350,000 tons?
Q122	HH	Can a landfill ever stop reporting under the rule?
Q123	Y	For petroleum refineries, which subpart should be followed for flare calculations? Section 98.252(a) says to use Subpart C. However, section 98.253(b) specifies a method for flares.
Q125	AA	The definition of the source category for Pulp and Paper is relatively broad to include a range of pulp and paper manufacturing activities. If a facility falls under the definition of 98.270 (a) but does not contain emission units specified in 98.270(b) for which greenhouse gas emissions must be reported, is such a facility subject Subpart AA?
Q126	A	If a campus is divided by several blocks of property not owned by the entity – can that area be defined as a facility by itself?
Q127	A	If a campus is divided by a non-owned body of water (e.g., a river), does that create two distinct facilities?
Q129	A	I leased space within my definition of "facility", if I do not track fuel use for that space, do I have to include it in my report?
Q130	A	I have space which I own, but lease to a third party within my "facility" and the tenant pays the utilities, do I have to include that building space?
Q131	A	Some entities may choose to report all greenhouse emissions for ease of data management, even if some sources do not meet the definition of "facility" and exceed the threshold. If cap and trade rules on greenhouse gas emissions are promulgated in the future and GHG Reporting Rule data is used to establish a cap and trade system, could you speculate whether entities would be able to restate their emissions?
Q132	A	Provide one or two specific examples of what would be acceptable to EPA under §98.3(g)(5)(i)(B), "Explanation of processes and methods used to collect the necessary data for the GHG calculations".
Q133	C	Can I use more than 1 Tier Method for my facility?
Q134	C	I have a natural gas emergency generator and a boiler in a building within the facility but no means to separate the usage out – how do I account for that, since the e-gen is not included?
Q135	C	I have natural gas meter records for a building that uses natural gas for heating and cooking – but no separate meters – how do we account for that?
Q137	C	I do not have a fuel meters at a building on the source, but know how much fuel is delivered. This is not the actual amount used, since my inventory at the beginning of the year may be different than the end – should I use the delivered amount?
Q138	C	Please explain what High Heat Value (HHV) testing is and how a school's EH&S personnel would know if this is occurring?
Q139	C	Would a boiler (or other combustion unit) that is mounted on a trailer or movable platform, that is used to provide temporary services while facility equipment is serviced, upgraded, or replaced, and where such equipment remains at the facility...
Q140	C	Would the following be considered stationary or portable sources, assuming their location falls within the definition of facility?
Q141	HH	My site has a gas collection system, which equations do I need to calculate to determine my methane generation and GHG emissions?
Q142	A	In the event fuel volume is based on third-party fuel billing meters that meet the exemption in 98.3(i)4, what are the record keeping requirements?
Q148	C	With respect to coal or fuel oil, the rule requires analysis of at least one representative sample from each lot. Does EPA have any additional guidance on what constitutes a "lot?"
Q151	HH	Must every container or vehicle be weighed coming in and going out of the landfill?
Q153	HH	Does EPA accept thermal flow meters for measuring volumetric flow rate of LFGs?
Q154	HH	What additional considerations are necessary when using a mass flow meter for landfill gas?
Q155	A	How did EPA use input from stakeholders in the development of the proposed rule amendments?
Q164	MM	A third party measures the quantity of a petroleum product I receive with equipment that is not located on my site. Am I allowed to use that data to report quantity in my annual GHG report? Who is responsible for retaining the associated records? Who is responsible for the accuracy of that measurement?
Q165	MM	What is an industry standard practice, and when can one be used? How should I report an industry standard practice? Is "third party verification" or "delivery record" an industry standard practice?
Q166	MM	The quantity of petroleum product that I import is determined by a third party gauger who is approved by Customs & Border Protection (CBP). How should I comply with the quantity determination requirements in §98.393(a)?
Q167	MM	If my refinery sells a fuel product to a pipeline company that is measured by a custody transfer meter that is owned and operated solely by the customer, can I define this meter as a "fuel gas billing meter" as in subpart A §98.3 \(i) (4), which says: "Fuel billing meters are exempted from the calibration requirements of this section, provided that the fuel supplier and any unit combusting the fuel do not have any common owners and are not owned by subsidiaries or affiliates of the same company."
Q168	MM	Am I required to report under subpart MM even though my refinery does not input any crude oil?
Q169	MM	Does the rule cover imports into and exports from all U.S. possessions, including Puerto Rico, Guam, U.S. Virgin Islands, and other U.S. territories?
Q170	MM	Does the rule require reporting for import shipments into a specified U.S. territory from another U.S. location, and export shipments from a specified U.S. territory to another U.S. location?
Q171	MM	If my refinery produces a product, feedstock or blendstock stream that is not listed in Table MM-1, how should I comply with the subpart MM reporting requirements? Am I required to use Calculation Method 2 to develop my own emission factor?
Q172	MM	Can a product-specific factor developed at one facility be used at another facility for the same type of product?
Q173	MM	What is meant by "otherwise used on site" for the subpart MM equations using feedstock quantities?
Q174	MM	How do I account for intermediate stocks that are traded between different refineries. For example, if I send gasoil to another location, do I account for it or do I only report finished products?
Q175	MM	What biomass activities are included in Equation MM-3, and in what cases should I subtract biomass out of equation MM-8?
Q176	MM	If a refinery imports and exports petroleum products, should these products be reported both at the facility level under §98.396(a) as well as at the corporate level under §98.396(b) and (c)?
Q178	OO	Are importers of HFCs required to obtain EPA approval before importing the HFCs into the U.S.?
Q179	A	Section 98.4(b) states the designated representative shall be an individual selected by an agreement binding on the owner or operator of the facility. What constitutes the "agreement"?
Q180	A	For subparts that were published on June 12, 2010, which are magnesium production (subpart T), underground coal mines (subpart FF), industrial wastewater treatment (subpart II) and industrial landfills (subpart TT), when is the Certificate of Representation (COR) due?
Q181	A	When are the requests for use of Best Available Monitoring Methods (BAMM) for subparts T, FF, II, and TT due?
Q182	A	For subparts T, FF, II, and TT, is the use of Best Available Monitoring Methods (BAMM) automatically allowed for the first quarter of 2011 (January 1, 2011 to March 31, 2011)?
Q183	LL	Under subpart LL, are coal-to-liquids facilities required to report on coal-based products that are solid products (such as coke), or is reporting limited to liquid products?
Q184	JJ	Can facilities with manure management systems report under the Greenhouse Gas Reporting Program?
Q185	e-GGRT Facility Registration	Can additional Agents be added to e-GGRT after Jan 30, 2011?
Q186	e-GGRT Facility Registration	Some of us are consultants who will be populating e-GGRT on behalf of our clients. Can you explain which role we should be assigned in e-GGRT?
Q187	Facility Registration	Is the technical person who prepares the information for signature the "Agent" in your terminology?
Q188	Facility Registration	Some reporters may have the Designated Representative (DR) and (ADR) at the plant, but a corporate employee will coordinate all the reporting. Can one employee be set up as an Agent for all plants?
Q189	Facility Registration	Can Agents be removed at anytime?
Q190	Facility Registration	Does an e-GGRT user have access to multiple facilities from one login if he or she is helping multiple clients?
Q191	Facility Registration	Can an Agent appoint another Agent?
Q192	Facility Registration	Can a contractor register for e-GGRT on behalf of a client? Or should it only be an employee?
Q193	Facility Registration	Is there a limit to the number of Agents or Alternate Designated Representatives (ADR) for any one company?
Q194	Facility Registration	I am a technical professional who will be preparing the report for my plant manager to certify. Should we both go through the process for setting up a user profile? Can I be set up as a user even though I will not certify the submission?
Q195	Facility Registration	Must the Designated Representative (DR) and Alternate Designated Representative (ADR) appoint the same Agents?
Q196	Facility Registration	Is it possible for an Agent to prepare annual greenhouse gas (GHG) reports as well as submit reports?
Q197	Facility Registration	Do Agents need to be set up by the Designated Representative (DR) and Alternate Designated Representative (ADR)?
Q198	Facility Registration	Does the person setting up have access to our facility data in e-GGRT?
Q199	Facility Registration	What address information should be entered for suppliers reporting at the company level?
Q200	e-GGRT (General)	What are e-GGRT system requirements?
Q69	C	Does fuel use for comfort heating and hot water heaters need to be reported?
Q201	e-GGRT (General)	How do I turn on Javascript in my browser?
Q202	e-GGRT (General)	Will my browser back button work when using e-GGRT?
Q203	e-GGRT (General)	Will e-GGRT timeout due to inactivity? When does e-GGRT save?
Q204	User Registration	I am a CAMD Business System (CBS) user. What information will be imported to e-GGRT during user registration?
Q205	User Registration	Are the Certificates of Representation still required to be submitted by Jan 30, 2011 (for reporting year 2010), if EPA has the current Designated Representative (DR) registered in CAMD Business System (Part 75 CAIR)?
Q206	User Registration	If someone has both a CAMD Business System user account and a CDX account which one do they use to log in to e-GGRT?
Q207	e-GGRT (General)	I use both CAMD Business System (CBS) and e-GGRT. Which system should I use to update my user or facility profile?
Q208	User Registration	I am the Designated Representative (DR) in CAMD Business System (CBS). Do I need to be the first user to log in to e-GGRT for my facility or can someone else log in first?
Q209	User Registration	Is it mandatory to link the CAMD Business System Designated Representative (DR) user account with the e-GGRT DR user account?
Q210	User Registration	Why can't I find my CAMD Business System (CBS) facility in the facility search page?
Q211	e-GGRT (General)	I report emissions using ECMPS and CAMD Business System (CBS). Do I also have to submit reports using e-GGRT?
Q81	C	If a combustion unit is greater than 250 mmBtu per hour, combusts a biomass fuel listed in Table C-1, and receives HHV data at the required frequency in §98.34(a), may Tier 1 be used per 40 CFR 98.33(b)(1)(iii)?
Q212	e-GGRT (General)	Do you expect that most current CDX users will become e-GGRT users?
Q213	e-GGRT (General)	If I complete user registration in e-GGRT, can I use my e-GGRT user ID and password to log in to CDX?
Q214	Facility Registration	Does the Designated Representative (DR) have to be a vice president? Can an environmental manager prepare reports?
Q215	Facility Registration	Can the Alternate Designated Representative (ADR) create a user profile before a Designated Representative (DR)?
Q216	Facility Registration	How does a consultant enter data for a client who is the Designated Representative (DR)? What does a consultant do on the DR and Alternate Designated Representative (ADR) screen, since the consultant is neither the DR nor authorized to appoint the DR.
Q217	Facility Registration	Can a company designate more than one Alternate Designated Representative (ADR)?
Q218	e-GGRT (General)	Does facility data have to be entered manually or can you upload the data using files?
Q219	Facility Registration	So, if I understand correctly, I can register and appoint myself as the Alternate Designated Representative (ADR) and my boss as the Designated Representative (DR), but I will not get an invitation to accept the appointment until he registers and accepts?
Q220	Facility Registration	What is the process for changing a Designated Representative (DR) or Alternate Designated Representative (ADR)?
Q221	Facility Registration	Like the Electronic Signature Agreement, does the Certificate of Representation need to be printed out, signed and mailed to EPA?
Q222	Facility Registration	Does a Designated Representative (DR) need to grant or appoint a consultant access to their facility?
Q223	Facility Registration	Can an ADR be appointed after Jan 30, 2011?
Q224	Facility Registration	For the Environmental Mgr to become the Designated Representative (DR) does he or she need a formal letter from the facility owners? Does that letter need be submitted with the signature page?
Q225	Facility Registration	Can an e-GRRT user enter in (but not sign, submit) all facility greenhouse gas (GHG) emissions without being a Designated Representative (DR), Alternate Designated Representative (ADR) or Agent?
Q226	Facility Registration	The Designated Representative (DR) may appoint one Alternate Designated Representative (ADR) at each facility or supplier. If my operation is both a facility and a supplier can the DR be two different people, one for the facility and one for the supplier?
Q96	C	Is there a recurring fuel flow meter calibration requirement for Tier 1 and Tier 2 units?
Q227	Facility Registration	What is the difference between a Designated Representative (DR) and Alternate Designated Representative (ADR), and an Agent?
Q97	C	Does the calibration exemption for fuel billing meters still apply for common pipe reporting option?
Q228	Facility Registration	What events require the Designated Representative (DR) or Alternate Designated Representative (ADR) to resubmit a Certificate of Representation for the facilities they represent?
Q229	e-GGRT (General)	What is e-GGRT?
Q231	e-GGRT (General)	When will EPA offer training on e-GGRT?
Q232	e-GGRT (General)	Will EPA provide the opportunity to review e-GGRT, provide input and beta test?
Q233	e-GGRT (General)	Do I have to use e-GGRT to report to the Greenhouse Gas Reporting Program (GHGRP)? Are there any source categories that will not use e-GGRT?
Q234	e-GGRT (General)	Will e-GGRT and the XML Reporting Schema v1.0 account for reporting requirements proposed or promulgated for reporting year 2011?
Q146	C	Many facilities use mass or volumetric flow meters to measure gaseous streams. Please confirm whether it is acceptable to use a mass flow meter to determine the volumetric flow rate of gaseous streams under Subpart C or the GHG Reporting Rule.
Q236	e-GGRT (General)	During what hours is telephone support available? Will hours be extended during busy times?
Q237	e-GGRT (General)	Do Greenhouse Gas Reporting Program (GHGRP) reporters have to submit Monitoring Plans?
Q149	C	If coal comes from the same source, how many deliveries must be analyzed to have a representative sample?
Q238	e-GGRT (General)	Where should I submit rule related questions on Part 98?
Q239	e-GGRT (General)	How do I contact the e-GGRT Help Desk?
Q308	C	How do you report in e-GGRT a fuel that changed calculation methodology from Tier 1 to Tier 2 for a given configuration during the middle of the year?
Q240	User Registration	The address shown for the Electronic Signature Agreement submission looks like a street address. Can we send the Electronic Signature Agreement by via regular mail, certified mail or other express mail?
Q241	User Registration	Similar to Toxics Release Inventory (TRI), does only the certifier need to complete the Electronic Signature Agreement or do all users and Agents?
Q242	User Registration	Will it be possible to get a copy of the e-GGRT Terms and Conditions so I can review them in advance?
Q243	User Registration	If a single individual will be entering information for multiple facilities, can a single Electronic Signature Agreement be submitted to cover all facilities or will multiple Electronic Signature Agreements need to be submitted?
Q245	User Registration	If I've already submitted an Electronic Signature Agreement for my CDX account, do I have to submit another one for e-GGRT?
Q246	User Registration	If I've submitted an Electronic Signature Agreement for my CAMD Business System account, will that work for e-GGRT?
Q247	User Registration	To what address do I send the Electronic Signature Agreement?
Q248	User Registration	My Electronic Signature Agreement is lost. How do I print a new copy and mail it in?
Q249	User Registration	Why would EPA reject an Electronic Signature Agreement?
Q251.	Facility Registration	What if I can't find my facility or supplier on the e-GGRT facility search page? Will e-GRRT provide the ability to add a new facility?
Q252	Facility Registration	Does the facility registration process need to be completed in one session like the user registration process?
Q253	Facility Registration	Will suppliers of fossil fuels (such as natural gas local distribution companies) follow the same procedure to set up a companywide Certificate of Registration?
Q254	Facility Registration	Our operation includes a supplier under one subpart and a facility under another. Do they have to have the same Designated Representative (DR)?
Q255	e-GGRT (General)	What is XML?
Q256	User Registration	Do Agents have a different login and password from the Designated Representative (DR)?
Q257	User Registration	What happens if you do not complete user registration in one session? Can you start again later?
Q258	User Registration	Does e-GGRT allow an international address in the user profile?
Q259	User Registration	Is there a mechanism to support multiple companies from a single email address?
Q260	User Registration	How often do I need to change my e-GGRT password?
Q261	User Registration	I forgot my e-GGRT user name. How do I retrieve it?
Q262	User Registration	I lost my password. How can I get it reset?
Q263	User Registration	How do I reset my expired password?
Q264	User Registration	How do I unlock my e-GGRT account?
Q265	User Registration	During user registration, I already provided a secret question and answer. Why do I also need challenge questions and answers?
Q267	Facility Registration	If there is a change in owner or operator, does e-GGRT need to be updated within 90 days?
Q268	e-GGRT (General)	The ten minute inactivity timeout in e-GGRT makes me nervous. Can I save as I go?
Q269	User Registration	If I submit data only once a year, why does the password expire every 90 days?
Q270	Facility Registration	Where can I find the Certificate of Representation to file?
Q271	Facility Registration	If a Designated Representative's (DR) or Alternate Designated Representative's (ADR) password expires, will their Agents still be able to access and work in e-GGRT?
Q272	Facility Registration	Must a large company with multiple facilities in different states have one Designated Representative (DR) for all facilities, or can each facility have its own DR?
Q273	Facility Registration	Is there any way to be the Agent for all facilities at a company and fill out only one Notice of Delegation?
Q274	Facility Registration	If you want someone to be able to prepare an electronic report but not submit, what role should they have?
Q275	Facility Registration	If the Designated Representative (DR) or Alternate Designated Representative (ADR) changes at a facility but no Agents change, must the DR or ADR submit new a Notice of Delegation for each Agent?
Q277	User Registration	Can you log in to e-GGRT with your ECMPS user name and password?
Q278	A	My facility has completed its use of best available monitoring methods (BAMM) and is now fully following the methods in the final rule. Do and I need to notify EPA of this change?
Q279	PP	To measure the composition of the CO2 stream, am I limited to the two methods listed in 40 CFR part 98.424(b)(2)?
Q283	Facility Registration	What address information should be entered for facilities with no street or mailing address?
Q284	A	The definition of "owner" and "operator" under 98.6 refers to a "person." Is a person only a single individual?
Q285	Facility Registration	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?
Q286	NN	If a natural gas supplier has companies it owns in different states, can the supplier report all of the companies together or should they be separated by state or company name?
Q287	OO	How does one handle the calculation of blends such as R-410A? Do we calculate on the basis of the components, e.g., HFC-125 and HFC-32?
Q288	FF	Do small, non-gassy mines need to report MSHA samples quarterly even though they are not specifically required to?
Q289	NN	The rule states that LDCs need to report under subpart NN if they delivered more than 460,000 Mscf in 2010. How should an LDC determine if it "delivered" more than 460,000 Mscf in 2010? Does this include quantities delivered to other LDCs and/or large end-users? What about natural gas placed into/removed from storage?
Q291	O	On March 18, 2011, EPA extended the deadline for reporting 2010 GHG data from March 31, 2011 to September 30, 2011. Does this extension also apply to the one-time reports that are due on March 31, 2011, and that are required under subpart O at §98.156(e)? If not, then how and where should these reports be submitted?
Q150	HH	Are scales required for Municipal Solid Waste Landfills?
Q292	OO	On March 18, 2011, EPA extended the deadline for reporting 2010 GHG data from March 31, 2011 to September 30, 2011. Does this extension also apply to the one-time reports that are due on March 31, 2011, and that are required under subpart OO at §98.416(b), (e), and (f)? If not, then how and where should these reports be submitted?
Q293	Sandbox Testing	Can I submit my annual GHG report during the Sandbox testing?
Q294	Sandbox Testing	Will data entered during Sandbox testing be saved by EPA?
Q295	Sandbox Testing	Will data I enter during Sandbox testing be subject to public information disclosure requests?
Q296	Sandbox Testing	Should I enter my actual emissions information during Sandbox testing?
Q297	Sandbox Testing	If I note a problem with e-GGRT during Sandbox testing what should I do?
Q298	Sandbox Testing	I notice that there are no webinars scheduled for several subparts for which I will be reporting. Does this mean that I'll be unable to test these subparts during Sandbox testing?
Q299	A	What does EPA mean by the term "sequential or simultaneous" in the definition of co-generation?
Q300	Sandbox Testing	Is the e-GGRT Sandbox testing different than the beta testing of e-GGRT?
Q301	Sandbox Testing	Does the Sandbox testing period just give the user an early look at how e-GGRT will work?
Q302	Sandbox Testing	Are there specific tasks that the Sandbox users must complete during their testing period?
Q303	e-GGRT (General)	Have any of the equations under the GHG reporting rule been revised, or have any new equations been added since the rule was finalized in 2009?
Q304	e-GGRT (General)	When asked in e-GGRT if a unit has a CEMS, is it specifically referring to a CO2 CEMS?
Q305	e-GGRT (General)	Does the information from the Reporting Forms populate e-GRRT fields or are they just uploaded files? If automatically populated, are these values available for review before submitting the report?
Q306	e-GGRT (General)	When will the reporting tools for subparts I, L, T, W, DD, FF, II, QQ, SS, TT, and UU be available?
Q307	C	How do you report a unit in e-GGRT that uses Tier 2 or 3 for part of the year and CEMS for the remainder of the year?
Q309	D	Will e-GGRT import any data from Electronic Data Reports (EDRs) or CAMD?
Q310	AA	For subpart AA in e-GGRT, on the screen to enter CO2 emissions from makeup chemicals, why are there two boxes to check?
Q311	AA	For subpart AA in e-GGRT, can a reporter add multiple instances of makeup chemical use?
Q312	e-GGRT Confidential Business Information (CBI)	Will the data I submit in e-GGRT be treated as CBI?
Q313	e-GGRT Confidential Business Information (CBI)	Can I mark my data as CBI in e-GGRT?
Q314	e-GGRT Confidential Business Information (CBI)	Can I designate data as CBI in my XML file?
Q315	e-GGRT Confidential Business Information (CBI)	EPA has said that data submitted during the testing period will not be treated as confidential. Is there a risk that data submitted during testing will be made publicly available?
Q316	e-GGRT Confidential Business Information (CBI)	The interim final rule published in December 2010 deferred reporting of inputs until August 31, 2011, but the 2011 reporting deadline is now September 30, 2011. How is this handled in e-GGRT?
Q317	e-GGRT Confidential Business Information (CBI)	Are inputs to emission equations being collected in e-GGRT?
Q318	e-GGRT Confidential Business Information (CBI)	Should reporters include calculation inputs when they upload XML files?
Q319	e-GGRT Confidential Business Information (CBI)	Are reporters required to use the calculation spreadsheets provided by EPA or may they use their own spreadsheets?
Q320	e-GGRT Confidential Business Information (CBI)	Should reporters using the calculation spreadsheets submit them to EPA?
Q321	A	Does the roll-up calculator distinguish between direct emitters and suppliers?
Q322	C	To what precision should emission values for CO2, N2O, and CH4 be reported in e-GGRT?
Q323	C	If I am only reporting subpart C emissions for the 2010 reporting year, am I allowed to use the subpart C abbreviated reporting module?
Q324	C	If a facility is eligible to use the subpart C abbreviated reporting form, is it required to or may it use the full subpart C reporting form?
Q325	C	What are biogenic emissions?
Q326	C	What are non-biogenic emissions?
Q327	C	If multiple subparts apply to our sources such as subparts A, C, and D, are we reporting data under all three subparts?
Q328	C	For Tier 4 configurations, if there is no missing data, do you still have to report total operating hours in the reporting year and zeros for hours in which substitute data was use?
Q329	C	Is a blend of natural gas and biogas a unique fuel type that must be added?
Q330	C	If a natural gas common pipe is connected to a series of small combustion units and a subpart D unit, how should emissions be reported?
Q331	C	Am I required to report emissions for emergency generators?
Q332	C	Is there a limit on the number of units or fuel types listed for an aggregation of units configuration?
Q333	C	Can you change configuration types from year to year?
Q334	C	Is there any flexibility in deciding what configuration type I can use for a unit or group of units?
Q335	C	Am I required to enter emissions for each fuel type?
Q337	C	If a facility is permitted to burn fuel of a certain type, is it required to identify that fuel type in e-GGRT?
Q338	C	For Tier 3, if I have multiple combustion sources using a single fuel type, should I enter this as an aggregation of units?
Q339	D	Will a subpart D unit that co-fires biogas have to set up both Subpart D and C modules to calculate the biogenic CO2 per 98.33?
Q340	D	Are CAIR units part of Subpart D reporting?
Q341	P	Does subpart P require me to account for ammonia emitted as an air emission?
Q342	Y	Are you required to submit information for all of the "facility-level emissions" categories within Subpart Y, even if no emissions exist for some categories?
Q345	Y	For storage tank emissions reported in Subpart Y, do you enter aggregate emissions or emissions on a tank-by-tank basis?
Q346	AA	Is a paper making company required to report GHG emissions under Subpart AA if the only source of emissions is on -site combustion?
Q347	HH	What is meant by manufacturer of gas collection system?
Q348	HH	What if two methods are used to estimate waste disposal quantities in a single year? How does a reporter indicate that in e-GGRT?
Q349	HH	The questions on reporting where gas is destroyed seem to consider only 2 options - either entirely on-site or entirely off-site. What if some gas is sent off-site and the rest is consumed on-site?
Q350	HH	What if I have more than one landfill or more than one cell at my facility, one is closed, one is open, and each has different waste content?
Q351	HH	Have any of the equations been revised, or have any new equations been added since Subpart HH was finalized in 2009?
Q352	HH	What are definitions of wet and dry gas in subpart HH?
Q353	HH	If a LFG flow meter malfunctions and is out for service for a week or two, are we required to have a backup meter or can we use the estimating missing data provisions of 98.345 to estimate the gas volumes during the period that the meter was not in place?
Q354	HH	Do the emission formulas differ from those used in LandGEM?
Q355	HH	Do we have to use the quantity of waste disposed of for every year since 1960 to calculate the modeled CH4 generation rate?
Q356	HH	How far back in the past do we answer questions about the facility? How do we handle unknown information when the site was owned by someone prior?
Q357	HH	A site has 3 cells. Cells 1 and 2 have active LFG collection systems and cell 3 does not, how do we proceed?
Q358	HH	Did you say if we have an MSW with other parts we don't have to count those parts towards our methane generation if they were another type of landfill? (i.e., a C & D portion)? I assume I heard that wrong.
Q359	HH	If the landfill accepts only incinerator ash (inert) and does not generate gas, should we consider reporting the quantities of ash?
Q360	HH	How do you address a landfill which may have portions of lined area and others that are not lined for the same landfill?
Q361	HH	I am required to provide the values of Eq. HH-5 - HH-8. How are the depth waste data used?
Q362	HH	How do we account for highly variable designs i.e. pre and post Subtitle D, with variable depths and different cover cross-sections?
Q363	OO	Does the information from the Reporting Forms populate e-GRRT fields or are they just uploaded files? If automatically populated, are these values available for review before submitting the report?
Q364	OO	How do I calculate addition to the "net supply"?
Q365	OO	Why do net additions of GHGs have to be added manually when they already exist in the uploaded
Q366	OO	Can we upload multiple copies of the same file if we have more than 10 processes? How will eGGRT know that the second copy is a report for processes 11-20 and not just an overwrite of the report filed for processes 1-10? For more than 10 production processes and multiple forms, can we just fill out Part 2 of the additional forms (process information, not facility information)?
Q367	Sandbox Testing	When will the Data Reporting tab be available to start entering data?
Q368	Sandbox Testing	Is there a way to develop the data input needed for reporting during the Sandbox testing, save it, and then use it when performing the actual emission reporting?
Q369	Sandbox Testing	Do you have to be associated with a registered facility to perform the Sandbox testing or can you enter data into a fictional facility?
Q370	Sandbox Testing	Is there a deadline for signing up for Sandbox testing?
Q371	Sandbox Testing	During Sandbox testing, do we create our own facility or do we use the facility provided by EPA?
Q372	Sandbox Testing	Will everyone be able to be in the Sandbox facility at the same time? And will we see each other's entries?
Q373	Sandbox Testing	Does my existing user name and password get me into the Sandbox?
Q374	Sandbox Testing	How do we train our "leadership" to sign and submit if this capability is disabled in the Sandbox? Will there be printed or PDF instructions with screen shots and flow diagrams for these steps?
Q375.	Sandbox Testing	In the Sandbox, will I be able to test both the XML upload capability and the web forms on my one test facility?
Q376	Sandbox Testing	Since the Sandbox only allows for one facility is there a simple way to clear all entered data and start over to test different types of facilities?
Q377	Sandbox Testing	During the Sandbox testing, will we be able to create any number of units or groups with different subparts?
Q378	Sandbox Testing	In the Sandbox, can we submit more than once for a facility?
Q379	Sandbox Testing	Can we test web forms using our facility, and at a later date repeat the test using a different data set? Or, do we have only one chance to test with data?
Q380	Sandbox Testing	This Sandbox testing doesn't cover Subpart LL and MM, correct? I haven't gone through the website in detail yet - are there any webinars or Sandbox testing opportunities for entering data for Subparts LL or MM?
Q381	Sandbox Testing	When the report bug or problem link is clicked, will it keep the page we're on open?
Q382	Sandbox Testing	Will there only be any additional testing opportunities after the June Sandbox testing period and before the first reporting deadline on September 30, 2011?
Q383	Sandbox Testing	Is there a chance that any of the calculation spreadsheets will be revised between the Sandbox testing and when e- GGRT is available for actual reporting?
Q384	Sandbox Testing	Will all subparts be available during the Sandbox testing?
Q385	Sandbox Testing	Might the XML schema change as a result of Sandbox testing?
Q386	Sandbox Testing	My XML report generation tool will not be ready until late in the year. Can I access the Sandbox at that time?
Q387	L	Are processes with scrubbers that decompose F-GHGs required to submit the one-time report required by §98.126i, even though they have no combustion control device and do not technically emit "PICs" from the scrubber vent ?
Q388	A	Who must submit requests and one-time reports to EPA under Part 98?
Q389	HH	Within e-GGRT, how would a landfill handle multiple destruction devices including a portion of the gas sent off-site for destruction? Is there a way to add multiple on-site destruction devices for a gas system?
Q390	OO	How do I report imports and exports of refrigerant blends that contain both HCFCs and HFCs?