FAQ No.	Topic Area	Question
200	Q200	e-GGRT (General)	What are e-GGRT system requirements?
201	Q201	e-GGRT (General)	How do I turn on Javascript in my

browser? |

202

Q202

e-GGRT (General)

Will my browser back button

work when using e-GGRT? |

203

Q203

e-GGRT (General)

Will e-GGRT timeout

due to inactivity? When does e-GGRT save? |

207

[Q207

Q207. I use both CAMD Business System (CBS) and e-GGRT. Which system should I use to update my user or

facility profile?] | 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? |

211

[Q211

Q211. I report emissions using ECMPS and CAMD Business System (CBS). Do I also have to submit reports using

e-GGRT?] | e-GGRT (General) | I report emissions using ECMPS and CAMD Business System (CBS). Do I also have to submit reports

using e-GGRT? |

212

Q212

e-GGRT (General)

Do you expect

that most current CDX users will become e-GGRT users? |

213

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? |

218

Q218

e-GGRT

(General) | Does facility data have to be entered manually or can you upload the data using files? |

229	Q229	e-GGRT (General)	What is e-GGRT?
231	Q231	e-GGRT (General)	When will EPA offer training on e-GGRT?
232	[Q232 ]	e-GGRT (General)

Will EPA provide the opportunity to review e-GGRT, provide input and beta test? |

233

[Q233

Q233. 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?] | 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? |

234

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? |

236

[Q236 ]

e-GGRT

(General) | During what hours is telephone support available? Will hours be extended during busy times? |

237

Q237

e-GGRT

(General) | Do Greenhouse Gas Reporting Program (GHGRP) reporters have to submit Monitoring Plans? |

238

Q238

e-GGRT (General)

Where should I submit

rule related questions on Part 98? |

239	Q239	e-GGRT (General)	How do I contact the e-GGRT Help Desk?
255	Q255	e-GGRT (General)	What is XML?
268	[Q268 ]	e-GGRT (General)

The ten minute inactivity timeout in e-GGRT makes me nervous. Can I save as I go? |

303

[Q303

Q303. 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?] | 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? |

304

Q304

e-GGRT

(General) | When asked in e-GGRT if a unit has a CEMS, is it specifically referring to a CO2 CEMS? |

305

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? |

306

[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? |

312

Q312

e-GGRT Confidential Business Information (CBI)

Will the data I submit in e-GGRT be treated as CBI? |

313

Q313

e-GGRT Confidential Business Information (CBI)

Can I mark my

data as CBI in e-GGRT? |

314

Q314

e-GGRT Confidential Business Information (CBI)

Can I

designate data as CBI in my XML file? |

315

[Q315

Q315. 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?] | 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? |

316

[Q316

Q316. 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?] | 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? |

317

[Q317 ]

e-GGRT Confidential Business Information

(CBI) | Are inputs to emission equations being collected in e-GGRT? |

318

[Q318 ]

e-GGRT Confidential Business

Information (CBI) | Should reporters include calculation inputs when they upload XML files? |

319

[Q319

Q319. Are reporters required to use the calculation spreadsheets provided by EPA or may they use their own

spreadsheets?] | e-GGRT Confidential Business Information (CBI) | Are reporters required to use the calculation spreadsheets

provided by EPA or may they use their own spreadsheets? |

320

Q320

e-GGRT Confidential Business

Information (CBI) | Should reporters using the calculation spreadsheets submit them to EPA? |

185

[Q185 ]

e-GGRT Facility Registration

Can

additional Agents be added to e-GGRT after Jan 30, 2011? |

186

[Q186

Q186. 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?] | 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? |

187

Q187

Facility Registration | Is the technical person who prepares the information for signature the "Agent" in your terminology? |

188

[Q188

Q188. 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?] | 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? |

189	[Q189 ]	Facility Registration	Can Agents be removed at anytime?
190	[Q190	Q190. Does an e-GGRT user have access to multiple facilities from one login if he or she is helping multiple

clients?] | Facility Registration | Does an e-GGRT user have access to multiple facilities from one login if he or she is

helping multiple clients? |

191	Q191	Facility Registration	Can an Agent appoint another Agent?
192	Q192

Facility Registration | Can a contractor register for e-GGRT on behalf of a client? Or should it only be an employee? |

193

[Q193

Q193. Is there a limit to the number of Agents or Alternate Designated Representatives (ADR) for any one

company?] | Facility Registration | Is there a limit to the number of Agents or Alternate Designated Representatives (ADR)

for any one company? |

194

[Q194

Q194. 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?] | 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? |

195

[Q195

Q195. Must the Designated Representative (DR) and Alternate Designated Representative (ADR) appoint the same

Agents?] | Facility Registration | Must the Designated Representative (DR) and Alternate Designated Representative (ADR)

appoint the same Agents? |

196

Q196

Facility Registration

Is it

possible for an Agent to prepare annual greenhouse gas (GHG) reports as well as submit reports? |

197

[Q197

Q197. Do Agents need to be set up by the Designated Representative (DR) and Alternate Designated

Representative (ADR)?] | Facility Registration | Do Agents need to be set up by the Designated Representative (DR) and

Alternate Designated Representative (ADR)? |

198

Q198

Facility Registration

Does

the person setting up have access to our facility data in e-GGRT? |

199

Q199

Facility

Registration | What address information should be entered for suppliers reporting at the company level? |

214

[Q214

Q214. Does the Designated Representative (DR) have to be a vice president? Can an environmental manager

prepare reports?] | Facility Registration | Does the Designated Representative (DR) have to be a vice president? Can an

environmental manager prepare reports? |

215

[Q215

Q215. Can the Alternate Designated Representative (ADR) create a user profile before a Designated

Representative (DR)?] | Facility Registration | Can the Alternate Designated Representative (ADR) create a user profile

before a Designated Representative (DR)? |

216

[Q216

Q216. 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.] | 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. |

217

Q217

Facility

Registration | Can a company designate more than one Alternate Designated Representative (ADR)? |

219

[Q219

Q219. 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?] |

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? |

220

[Q220

Q220. What is the process for changing a Designated Representative (DR) or Alternate Designated Representative

(ADR)?] | Facility Registration | What is the process for changing a Designated Representative (DR) or Alternate Designated

Representative (ADR)? |

221

[Q221

Q221. Like the Electronic Signature Agreement, does the Certificate of Representation need to be printed out,

signed and mailed to EPA?] | Facility Registration | Like the Electronic Signature Agreement, does the Certificate of

Representation need to be printed out, signed and mailed to EPA? |

222

Q222

Facility Registration | Does a Designated Representative (DR) need to grant or appoint a consultant access to their facility?

223	[Q223 ]	Facility Registration	Can an ADR be appointed after Jan

30, 2011? |

224

[Q224

Q224. 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?] | 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? |

225

[Q225

Q225. 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?] | 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? |

226

[Q226

Q226. 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?] | 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? |

227

[Q227

Q227. What is the difference between a Designated Representative (DR) and Alternate Designated Representative

(ADR), and an Agent?] | Facility Registration | What is the difference between a Designated Representative (DR) and Alternate

Designated Representative (ADR), and an Agent? |

228

[Q228

Q228. What events require the Designated Representative (DR) or Alternate Designated Representative (ADR) to

resubmit a Certificate of Representation for the facilities they represent?] | 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? |

251

[Q251

Q251. 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?] | 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? |

252

[Q252

Q252. Does the facility registration process need to be completed in one session like the user registration

process?] | Facility Registration | Does the facility registration process need to be completed in one session like the user

registration process? |

253

[Q253

Q253. Will suppliers of fossil fuels (such as natural gas local distribution companies) follow the same

procedure to set up a companywide Certificate of Registration?] | 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? |

254

[Q254

Q254. Our operation includes a supplier under one subpart and a facility under another. Do they have to have

the same Designated Representative (DR)?] | 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)? |

267

Q267

Facility

Registration | If there is a change in owner or operator, does e-GGRT need to be updated within 90 days? |

270

Q270

Facility Registration

Where can I find

the Certificate of Representation to file? |

271

[Q271

Q271. 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?] | 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? |

272

[Q272

Q272. 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?] | 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? |

273

[Q273

Q273. Is there any way to be the Agent for all facilities at a company and fill out only one Notice of

Delegation?] | Facility Registration | Is there any way to be the Agent for all facilities at a company and fill out only one

Notice of Delegation? |

274

[Q274

Q274. If you want someone to be able to prepare an electronic report but not submit, what role should they

have?] | Facility Registration | If you want someone to be able to prepare an electronic report but not submit, what role

should they have? |

275

[Q275

Q275. 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?] | 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? |

283

[Q283 ]

Facility

Registration | What address information should be entered for facilities with no street or mailing address? |

285

[Q285

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?] | 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? |

293

[Q293 ]

Sandbox Testing

Can I submit my

annual GHG report during the Sandbox testing? |

294

[Q294 ]

Sandbox Testing

Will data entered

during Sandbox testing be saved by EPA? |

295

[Q295 ]

Sandbox Testing | Will data I enter during Sandbox testing be subject to public information disclosure requests? |

296

[Q296 ]

Sandbox Testing

Should I

enter my actual emissions information during Sandbox testing? |

297

[Q297 ]

Sandbox Testing

If I note

a problem with e-GGRT during Sandbox testing what should I do? |

300

[Q300 ]

Sandbox Testing

Is the

e-GGRT Sandbox testing different than the beta testing of e-GGRT? |

301

[Q301 ]

Sandbox

Testing | Does the Sandbox testing period just give the user an early look at how e-GGRT will work? |

302

[Q302 ]

Sandbox

Testing | Are there specific tasks that the Sandbox users must complete during their testing period? |

367

[Q367 ]

Sandbox Testing

When will the

Data Reporting tab be available to start entering data? |

368

[Q368

Q368. 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?] | 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? |

369

[Q369

Q369. Do you have to be associated with a registered facility to perform the Sandbox testing or can you enter

data into a fictional facility?] | 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? |

370

[Q370 ]

Sandbox Testing

Is there a deadline for

signing up for Sandbox testing? |

371

[Q371 ]

Sandbox Testing | During Sandbox testing, do we create our own facility or do we use the facility provided by EPA? |

372

[Q372

Q372. Will everyone be able to be in the Sandbox facility at the same time? And will we see each other's

entries?] | Sandbox Testing | Will everyone be able to be in the Sandbox facility at the same time? And will we see each

other's entries? |

373

[Q373 ]

Sandbox Testing

Does my existing

user name and password get me into the Sandbox? |

374

[Q374

Q374. 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?] | 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? |

375

[Q375

Q375. In the Sandbox, will I be able to test both the XML upload capability and the web forms on my one test

facility?] | 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? |

376

[Q376

Q376. 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?] | 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? |

377

[Q377

Q377. During the Sandbox testing, will we be able to create any number of units or groups with different

subparts?] | Sandbox Testing | During the Sandbox testing, will we be able to create any number of units or groups with

different subparts? |

378

[Q378 ]

Sandbox Testing

In the Sandbox, can we

submit more than once for a facility? |

379

[Q379

Q379. 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?] | 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? |

380

[Q380

Q380. 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?] | 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? |

381

[Q381 ]

Sandbox Testing

When the report bug or problem link is clicked, will it keep the page we're on open?
382	[Q382	Q382. Will there only be any additional testing opportunities after the June Sandbox testing period and before

the first reporting deadline on September 30, 2011?] | 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? |

383

[Q383

Q383. 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?] | 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? |

384

[Q384 ]

Sandbox Testing

Will all subparts be

available during the Sandbox testing? |

385

[Q385 ]

Sandbox Testing

Might the XML schema

change as a result of Sandbox testing? |

386

[Q386

Q386. My XML report generation tool will not be ready until late in the year. Can I access the Sandbox at that

time?] | Sandbox Testing | My XML report generation tool will not be ready until late in the year. Can I access the Sandbox

at that time? |

204

[Q204

Q204. I am a CAMD Business System (CBS) user. What information will be imported to e-GGRT during user

registration?] | User Registration | I am a CAMD Business System (CBS) user. What information will be imported to e-GGRT

during user registration? |

205

[Q205

Q205. 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)?] | 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)? |

206

[Q206

Q205. 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)?] | 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? |

208

[Q208

Q208. 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?] | 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? |

209

[Q209

Q209. Is it mandatory to link the CAMD Business System Designated Representative (DR) user account with the

e-GGRT DR user account?] | User Registration | Is it mandatory to link the CAMD Business System Designated Representative

(DR) user account with the e-GGRT DR user account? |

210

Q210

User Registration

Why can't I

find my CAMD Business System (CBS) facility in the facility search page? |

240

[Q240

Q240. 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?] | 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? |

241

[Q241

Q241. Similar to Toxics Release Inventory (TRI), does only the certifier need to complete the Electronic

Signature Agreement or do all users and Agents?] | 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? |

242

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? |

243

[Q243

Q243. 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?] | 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? |

245

[Q245

Q245. If I've already submitted an Electronic Signature Agreement for my CDX account, do I have to submit

another one for e-GGRT?] | 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? |

246

[Q246

Q246. If I've submitted an Electronic Signature Agreement for my CAMD Business System account, will that work

for e-GGRT?] | User Registration | If I've submitted an Electronic Signature Agreement for my CAMD Business System account,

will that work for e-GGRT? |

247

Q247

User Registration

To what address do

I send the Electronic Signature Agreement? |

248

[Q248 ]

User

Registration | My Electronic Signature Agreement is lost. How do I print a new copy and mail it in? |

249

[Q249 ]

User Registration

Why would EPA reject an

Electronic Signature Agreement? |

256

Q256

User

Registration | Do Agents have a different login and password from the Designated Representative (DR)? |

257

Q257

User

Registration | What happens if you do not complete user registration in one session? Can you start again later? |

258

[Q258 ]

User Registration

Does e-GGRT allow

an international address in the user profile? |

259

Q259

User Registration

Is there a mechanism to support multiple companies from a single email address? |

260

Q260

User Registration

How often do I need to change

my e-GGRT password? |

261

Q261

User Registration

I forgot my e-GGRT user name.

How do I retrieve it? |

262

Q262

User Registration

I lost my password. How can I get it

reset? |

263	Q263	User Registration	How do I reset my expired password?
264	Q264	User Registration	How do I unlock my e-GGRT account?
265	[Q265	Q265. During user registration, I already provided a secret question and answer. Why do I also need challenge

questions and answers?] | User Registration | During user registration, I already provided a secret question and answer. Why

do I also need challenge questions and answers? |

269

Q269

User Registration

If

I submit data only once a year, why does the password expire every 90 days? |

277

Q277

User Registration

Can you log in

to e-GGRT with your ECMPS user name and password? |

1	[Q1 ]	Subpart A	What is the action being taken?
2	[Q2 ]	Subpart A	What is the purpose of the rule?
3	[Q3 ]	Subpart A	What is the effective date of the rule?
5	[Q5 ]	Subpart A	Who will have to report under the final rule?
7	Q7	Subpart A	Which greenhouse gases (GHGs) are

covered under the rule? |

9	[Q9 ]	Subpart A	Are mobile sources included in this rule?
10	Q10	Subpart A	What is the definition of a "facility"?
11	[Q11 ]	Subpart A	Will EPA collect

data at the unit-, facility-, or corporate-wide level? |

12

[Q12

Q12. 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] | Subpart 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? |

13

[Q13 ]

Subpart 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. |

14

[Q14 ]

Subpart A

What is the estimated cost to implement

this rule? |

15

[Q15 ]

Subpart A

What impact does this rule have on

small businesses? |

16

[Q16 ]

Subpart A

Did EPA engage stakeholders in

the development of the rule? |

17

[Q17 ]

Subpart A

Was my comment

submitted during the public comment period addressed? |

18	[Q18 ]	Subpart A	Is this rule a cap and trade regulation?
20	Q20	Subpart A	Does the rule apply to U.S. Territories?
21	[Q21	Q21. How did EPA develop the general threshold of 25,000 metric tons of carbon dioxide equivalent (mtCO2e) per

year?] | Subpart A | How did EPA develop the general threshold of 25,000 metric tons of carbon dioxide equivalent (mtCO2e)

per year? |

22

Q22

Subpart A

How much is 25,000 metric tons of

CO2 equivalent (mtCO2e)? |

23

[Q23

Q23. Are there some sectors where all facilities have to report regardless of whether they meet the 25,000

metric tons CO2e threshold?] | Subpart 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? |

25

[Q25 ]

Subpart A

Will all direct

emitters of greenhouse gases (GHGs) be included in the rule? |

26

[Q26

Q26. Is there a simple way for facilities with stationary fuel combustion units to determine if they will be

required to report?] | Subpart A | Is there a simple way for facilities with stationary fuel combustion units to determine if

they will be required to report? |

27

[Q27 ]

Subpart A

Will individual home

owners be required to report under this rule? |

28

[Q28 ]

Subpart A

Will individual car or truck

owners be required to report? |

29

[Q29 ]

Subpart A

Will owners of commercial

buildings be required to report? |

30

[Q30 ]

Subpart A

Will federal, state, or

local facilities have to report emissions? |

31

[Q31 ]

Subpart A

Are terrestrial carbon sequestration ("sinks") and offsets projects included in this rule? |

32

[Q32 ]

Subpart A

Why are both downstream and

upstream reporting required? |

33

[Q33 ]

Subpart A

Will there be double-reporting

of emissions under this rule? |

35

Q35

Subpart

A | How is the reporting of ethanol production and or biogenic emissions being handled in the rule? |

36

[Q36 ]

Subpart A | The Applicability Tool says I need to report, but I don't think the tool is right. Please confirm. |

37

Q37

Subpart A

Is applicability based on

actual emissions or potential emissions? |

42	[Q42 ]	Subpart A	How will emissions data be verified?
43	[Q43 ]	Subpart A	Will EPA provide training and guidance

for reporters? |

45

[Q45

Q45. 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?] | Subpart 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? |

50

Q50

Subpart A

When are reporters

required to complete their GHG Monitoring Plan? |

51

[Q51

Q51. What representative of a reporting facility is in charge of reporting? Is it the operator or facility

owner? Can a third partybe hired to report on behalf of the reporting facility?] | Subpart 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? |

53

[Q53 ]

Subpart A | Does this final rule preempt states from regulating or requiring reporting of greenhouse gases (GHGs)? |

54

[Q54 ]

Subpart A

Will data collection be delegated to

state agencies? |

56

[Q56

Q56. How is this reporting rule different from the Inventory of U.S. Greenhouse Gas Emissions and Sinks report

(Inventory)?] | Subpart A | How is this reporting rule different from the Inventory of U.S. Greenhouse Gas Emissions and

Sinks report (Inventory)? |

57

[Q57 ]

Subpart A	Will this rule negate the need for the Inventory of U.S. Greenhouse Gas Emissions and Sinks in the future?
58	[Q58 ]	Subpart A	Would this rule need to

be addressed in Title V operating permits? |

59

[Q59 ]

Subpart A

How could the

passing of the Waxman-Markey Bill affect this regulation? |

60

[Q60

Q60. 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?] | Subpart 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? |

61

[Q61

Q61. How will data be efficiently shared among existing state greenhouse gas (GHG) programs and this new federal

reporting program?] | Subpart A | How will data be efficiently shared among existing state greenhouse gas (GHG) programs and

this new federal reporting program? |

62

[Q62 ]

Subpart A

Where can I find more detailed

information on the rule? |

110

[Q110

Q110. If two entities share a Title V permit would that preclude them from reporting separately even if there

is no common ownership or control?] | Subpart 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? |

126

[Q126

Q126. 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?] | Subpart 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? |

127

[Q127

Q127. If a campus is divided by a non-owned body of water (e.g., a river), does that create two distinct

facilities?] | Subpart A | If a campus is divided by a non-owned body of water (e.g., a river), does that create two distinct

facilities? |

129

[Q129

Q129. 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?] | Subpart 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? |

130

[Q130

Q130. 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?] | Subpart 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? |

131

[Q131

Q131. Some entities may choose to report all greenhouse emissions for ease of data management. If cap and

trade rules on greenhouse gas emissions are promulgated , could you speculate whether entities would be able to restate their

emissions?] | Subpart 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? |

132

[Q132

Q132. 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".] | Subpart 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". |

142

[Q142

Q142. 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?] | Subpart 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? |

155

[Q155 ]

Subpart A

How did EPA use input from stakeholders in the development of the proposed rule amendments?
179	[Q179	Q179. 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"?] | Subpart 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"? |

180

[Q180 ]

Subpart 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? |

181

[Q181

Q181. When are the requests for use of Best Available Monitoring Methods (BAMM) for subparts T, FF, II, and TT

due?] | Subpart A | When are the requests for use of Best Available Monitoring Methods (BAMM) for subparts T, FF, II, and TT

due? |

182

[Q182

Q182. 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)?] | Subpart 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)? |

278

[Q278

Q278. 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?] | Subpart 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? |

284

[Q284

Q284. The definition of "owner" and "operator" under 98.6 refers to a "person." Is a person only a single

individual?] | Subpart A | The definition of "owner" and "operator" under 98.6 refers to a "person." Is a person only a

single individual? |

299

Q299

Subpart A | What does EPA mean by the term "sequential or simultaneous" in the definition of co-generation? |

321

[Q321 ]

Subpart A

Does the

roll-up calculator distinguish between direct emitters and suppliers? |

388

Q388

Subpart A

Who must submit

requests and one-time reports to EPA under Part 98? |

44

[Q44

Q44. 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?] | Subpart 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? |

64

[Q64 ]

Subpart C

Should pilot gas be included in

greenhouse gas calculations? |

66

Q66

Subpart C

Where does no. 2 diesel fuel fit

into Table C-1 and C-2? |

67

[Q67 ]

Subpart 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...? |

68

[Q68

Q68. 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...] | Subpart 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... |

200

Q69

Subpart C

Does fuel use

for comfort heating and hot water heaters need to be reported? |

70

[Q70

Q70. 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)?] | Subpart 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)? |

71

[Q71

Q71. 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?] | Subpart 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? |

72

[Q72

Q72. 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...?] | Subpart 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...? |

73

[Q73

Q73. 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?] | Subpart 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? |

74

[Q74

Q74. If a unit that combusts only fossil fuels has a CEMS for CO2 and uses Tier 4, must CO2 be reported by fuel

type?] | Subpart 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? |

75

[Q75

Q75. 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?] | Subpart 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? |

76

[Q76

Q76. 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?] | Subpart

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? |

77

[Q77

Q77. 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?] | Subpart 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? |

78

[Q78

Q78. 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?] | Subpart 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? |

80

[Q80

Q80. 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?] | Subpart 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? |

211

[Q81

Q81. 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)?] | Subpart 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)? |

82

[Q82

Q82. For a combustion turbine that only burns diesel oil and pipeline natural gas, is it acceptable to use

Tier 2 to calculate CO2 emissions?] | Subpart 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... |

83

Q83

Subpart 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? |

84

[Q84

Q84. 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?] | Subpart 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? |

85

[Q85

Q85. 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?] | Subpart 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? |

86

[Q86

Q86. 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?] | Subpart 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? |

87

[Q87

Q87. 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?] | Subpart 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? |

88

[Q88

Q88. 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...] | Subpart 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... |

89

[Q89

Q89. 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?] | Subpart 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? |

90

Q90

Subpart C

Does

EPA accept thermal flow meters for measuring volumetric flow rate under 98.34? |

91

[Q91

Q91. Are orifice, venturi, and nozzle flow meters required to have temperature, and total pressure

transmitters located on the flowmeters?] | Subpart C | Are orifice, venturi, and nozzle flow meters required to have

temperature, and total pressure transmitters located on the flowmeters? |

92

[Q92

Q92. 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?] | Subpart 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? |

93

[Q93

Q93. What should facilities do if the calibration error for fuel flow meters that exceeds the 5.0%

performance specification?] | Subpart C | What should facilities do if the calibration error for fuel flow meters that

exceeds the 5.0% performance specification? |

94

[Q94

Q94. 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?] | Subpart 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? |

95

[Q95

Q95. If a facility has a billing meter for natural gas for units throughout the facility and individual

units also have their own meters, is there an obligation under the rule to use the individual unit meters?] | Subpart 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... |

226

Q96

Subpart C

Is there a recurring fuel flow meter calibration requirement for Tier 1 and Tier 2 units?
227	Q97

Subpart C | Does the calibration exemption for fuel billing meters still apply for common pipe reporting option? |

133

Q133

Subpart C

Can I use more than 1 Tier Method

for my facility? |

134

[Q134

Q134. 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?] | Subpart 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? |

135

[Q135

Q135. 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?] | Subpart 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? |

137

[Q137

Q137. 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?] | Subpart 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? |

138

[Q138

Q138. Please explain what High Heat Value (HHV) testing is and how a school's EH&S personnel would know if

this is occurring?] | Subpart C | Please explain what High Heat Value (HHV) testing is and how a school's EH&S personnel

would know if this is occurring? |

139

[Q139

Q139. 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...] | Subpart 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... |

140

[Q140

Q140. Would the following be considered stationary or portable sources, assuming their location falls

within the definition of facility?] | Subpart C | Would the following be considered stationary or portable sources, assuming

their location falls within the definition of facility? |

235

[Q146

Q146. 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.] | Subpart 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. |

148

[Q148

Q148. 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?"] | Subpart 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?" |

237

[Q149

Q149. If coal comes from the same source, how many deliveries must be analyzed to have a representative

sample?] | Subpart C | If coal comes from the same source, how many deliveries must be analyzed to have a representative

sample? |

307

[Q307

Q307. 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?] | Subpart 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? |

239

[Q308

Q308. 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?] | Subpart 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? |

322

Q322

Subpart C

To what precision should emission values for CO2, N2O, and CH4 be reported in e-GGRT? |

323

[Q323

Q323. If I am only reporting subpart C emissions for the 2010 reporting year, am I allowed to use the

subpart C abbreviated reporting module?] | Subpart 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? |

324

[Q324

Q324. 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?] | Subpart 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? |

325	Q325	Subpart C	What are biogenic emissions?
326	[Q326 ]	Subpart C	What are non-biogenic emissions?
327	[Q327	Q327. If multiple subparts apply to our sources such as subparts A, C, and D, are we reporting data under

all three subparts?] | Subpart C | If multiple subparts apply to our sources such as subparts A, C, and D, are we reporting

data under all three subparts? |

328

[Q328

Q328. 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?] | Subpart 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? |

329

Q329

Subpart C

Is a blend of

natural gas and biogas a unique fuel type that must be added? |

330

[Q330

Q330. 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?] | Subpart 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? |

331

Q331

Subpart C

Am I required to report

emissions for emergency generators? |

332

[Q332

Q332. Is there a limit on the number of units or fuel types listed for an aggregation of units

configuration?] | Subpart C | Is there a limit on the number of units or fuel types listed for an aggregation of units

configuration? |

333

Q333

Subpart C

Can you change configuration

types from year to year? |

334

[Q334

Q334. Is there any flexibility in deciding what configuration type I can use for a unit or group of

units?] | Subpart C | Is there any flexibility in deciding what configuration type I can use for a unit or group of units? |

335

Q335

Subpart C

Am I required to enter emissions

for each fuel type? |

337

[Q337

Q337. If a facility is permitted to burn fuel of a certain type, is it required to identify that fuel type

in e-GGRT?] | Subpart C | If a facility is permitted to burn fuel of a certain type, is it required to identify that fuel

type in e-GGRT? |

338

[Q338

Q338. For Tier 3, if I have multiple combustion sources using a single fuel type, should I enter this as

an aggregation of units?] | Subpart C | For Tier 3, if I have multiple combustion sources using a single fuel type, should I

enter this as an aggregation of units? |

309

[Q309 ]

Subpart D

Will e-GGRT

import any data from Electronic Data Reports (EDRs) or CAMD? |

339

[Q339

Q339. 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?] | Subpart 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? |

340

[Q340 ]

Subpart D

Are CAIR units part of Subpart D

reporting? |

387

[Q387

Q387. 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 ?]

Subpart 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 ? |

291

[Q291

Q291. 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...] | 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? |

341

Q341

Subpart P

Does

subpart P require me to account for ammonia emitted as an air emission? |

123

[Q123

Q123. 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.] | Subpart 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. |

342

[Q342

Q342. 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?] | Subpart 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? |

345

[Q345

Q345. For storage tank emissions reported in Subpart Y, do you enter aggregate emissions or emissions on a

tank-by-tank basis?] | Subpart Y | For storage tank emissions reported in Subpart Y, do you enter aggregate emissions or

emissions on a tank-by-tank basis? |

125

[Q125

Q125. 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...] | Subpart 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? |

310

[Q310

Q310. For subpart AA in e-GGRT, on the screen to enter CO2 emissions from makeup chemicals, why are there

two boxes to check?] | Subpart AA | For subpart AA in e-GGRT, on the screen to enter CO2 emissions from makeup chemicals, why

are there two boxes to check? |

311

Q311

Subpart

AA | For subpart AA in e-GGRT, can a reporter add multiple instances of makeup chemical use? |

346

[Q346

Q346. Is a paper making company required to report GHG emissions under Subpart AA if the only source of

emissions is on -site combustion?] | Subpart AA | Is a paper making company required to report GHG emissions under Subpart AA

if the only source of emissions is on -site combustion? |

288

[Q288

Q288. Do small, non-gassy mines need to report MSHA samples quarterly even though they are not

specifically required to?] | Subpart FF | Do small, non-gassy mines need to report MSHA samples quarterly even though they

are not specifically required to? |

98

[Q98

Q98. 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?] | Subpart 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? |

100

Q100

Subpart HH

When does

moisture content need to be corrected for in Equation HH-4? |

102

Q102

Subpart HH

What

models are acceptable for performing the calculations in subpart HH? |

103

Q103

Subpart HH

How should inert wastes

be accounted for in Equation HH-1? |

104

Q104

Subpart HH | The methods listed in section 98.344 are not applicable to my monitor, how should I calibrate? |

105

[Q105

Q105. What is the definition of facility as it relates to landfills and landfill gas to electric (LFGTE)

plants?] | Subpart HH | What is the definition of facility as it relates to landfills and landfill gas to electric (LFGTE)

plants? |

106

[Q106

Q106. 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?] | Subpart 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? |

107

[Q107

Q107. If an MSW landfill has a dedicated area which receives waste other than MSW, may this area be

excluded from the rule requirements?] | Subpart HH | If an MSW landfill has a dedicated area which receives waste other than

MSW, may this area be excluded from the rule requirements? |

108

[Q108

Q108. If an MSW landfill is later remediated as a hazardous waste landfill, does it need to comply with

the rule?] | Subpart HH | If an MSW landfill is later remediated as a hazardous waste landfill, does it need to comply with

the rule? |

109

[Q109

Q109. 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?] | Subpart 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? |

111

[Q111

Q111. Do landfills have to report the biogenic CO2 that is included in LFG emissions and the CO2 that is

emitted from flares?] | Subpart HH | Do landfills have to report the biogenic CO2 that is included in LFG emissions and the

CO2 that is emitted from flares? |

112

[Q112 ]

Subpart HH

How does EPA

define "at least weekly" in the monitoring requirements? |

113

Q113

Subpart HH | If all of our landfill gas gets piped offsite to another facility, what do we need to report? |

114

Q114

Subpart HH

Can

an alternate oxidation factor, other than 10% be used in the calculations? |

116

[Q116

Q116. Do passive flares count as "gas collection systems" under the provision below? Do the landfills with

these systems have to collect data weekly?] | Subpart HH | Do passive flares count as "gas collection systems" under the

provision below? Do the landfills with these systems have to collect data weekly? |

117

[Q117

Q117. 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?] | Subpart 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? |

119

Q119

Subpart

HH | Are annubars or v-cone flowmeters acceptable for compliance with the rule requirements? |

120

Q120

Subpart HH

Is weekly

monitoring of both gas flow and methane concentration allowed? |

121

[Q121

Q121. 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?] | Subpart 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? |

122

Q122

Subpart HH

Can a landfill ever stop

reporting under the rule? |

141

[Q141

Q141. My site has a gas collection system, which equations do I need to calculate to determine my methane

generation and GHG emissions?] | Subpart HH | My site has a gas collection system, which equations do I need to calculate to

determine my methane generation and GHG emissions? |

291

Q150

Subpart HH

Are scales required for

Municipal Solid Waste Landfills? |

151

Q151

Subpart HH

Must every container or vehicle be weighed coming in and going out of the landfill? |

153

Q153

Subpart HH

Does

EPA accept thermal flow meters for measuring volumetric flow rate of LFGs? |

154

Q154

Subpart HH | What additional considerations are necessary when using a mass flow meter for landfill gas? |

347

Q347

Subpart HH

What is meant by

manufacturer of gas collection system? |

348

[Q348

Q348. What if two methods are used to estimate waste disposal quantities in a single year? How does a

reporter indicate that in e-GGRT?]
| Subpart 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? |

349

[Q349

Q349. 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?] | Subpart 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? |

350

[Q350

Q350. 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?] | Subpart 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? |

351

[Q351

Q351. Have any of the equations been revised, or have any new equations been added since Subpart HH was

finalized in 2009?] | Subpart HH | Have any of the equations been revised, or have any new equations been added since Subpart

HH was finalized in 2009? |

352

Q352

Subpart HH

What are definitions of wet

and dry gas in subpart HH? |

353

[Q353

Q353. 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...] | Subpart 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? |

354

Q354

Subpart HH

Do the emission formulas

differ from those used in LandGEM? |

355

[Q355

Q355. Do we have to use the quantity of waste disposed of for every year since 1960 to calculate the

modeled CH4 generation rate?] | Subpart HH | Do we have to use the quantity of waste disposed of for every year since 1960 to

calculate the modeled CH4 generation rate? |

356

[Q356

Q356. 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?] | Subpart 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? |

357

[Q357

Q357. A site has 3 cells. Cells 1 and 2 have active LFG collection systems and cell 3 does not, how do we

proceed?] | Subpart HH | A site has 3 cells. Cells 1 and 2 have active LFG collection systems and cell 3 does not, how do we

proceed? |

358

[Q358

Q358. 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.] | Subpart 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. |

359

[Q359

Q359. If the landfill accepts only incinerator ash (inert) and does not generate gas, should we consider

reporting the quantities of ash?] | Subpart HH | If the landfill accepts only incinerator ash (inert) and does not generate

gas, should we consider reporting the quantities of ash? |

360

[Q360

Q360. How do you address a landfill which may have portions of lined area and others that are not lined

for the same landfill?] | Subpart HH | How do you address a landfill which may have portions of lined area and others that

are not lined for the same landfill? |

361

[Q361 ]

Subpart HH | I am required to provide the values of Eq. HH-5 - HH-8. How are the depth waste data used? |

362

[Q362

Q362. How do we account for highly variable designs i.e. pre and post Subtitle D, with variable depths and

different cover cross-sections?] | Subpart HH | How do we account for highly variable designs i.e. pre and post Subtitle D,

with variable depths and different cover cross-sections? |

389

[Q389

Q389. 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?] | Subpart 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? |

19

[Q19

Q19. 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?] | Subpart 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? |

184

Q184

Subpart JJ | Can facilities with manure management systems report under the Greenhouse Gas Reporting Program? |

183

[Q183

Q183. 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?] | Subpart 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? |

164

[Q164

Q164. A third party measures the quantity of a petroleum product I receive with equipment that is not

located on my site. Who is responsible for retaining the associated records? Who is responsible for the accuracy of that

measurement?] | Subpart 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? |

165

[Q165

Q165. 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?] | Subpart 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? |

166

[Q166

Q166.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)?] |

Subpart 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)? |

167

[Q167

Q167. 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"...] | Subpart

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 (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." |

168

Q168

Subpart MM | Am I required to report under subpart MM even though my refinery does not input any crude oil? |

169

[Q169

Q169. 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?] | Subpart 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? |

170

[Q170

Q170. 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?] | Subpart 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? |

171

[Q171

Q171. 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?] | Subpart 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? |

172

[Q172

Q172. Can a product-specific factor developed at one facility be used at another facility for the same

type of product?] | Subpart MM | Can a product-specific factor developed at one facility be used at another facility for the

same type of product? |

173

Q173

Subpart MM	What is meant by "otherwise used on site" for the subpart MM equations using feedstock quantities?
174	[Q174	Q174. 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?] | Subpart 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? |

175

[Q175

Q175. What biomass activities are included in Equation MM-3, and in what cases should I subtract biomass

out of equation MM-8?] | Subpart MM | What biomass activities are included in Equation MM-3, and in what cases should I

subtract biomass out of equation MM-8? |

176

[Q176

Q176. 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)?] | Subpart 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)? |

286

[Q286

Q286. 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?] | Subpart 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? |

289

[Q289

Q289. 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 or removed from storage?] |

Subpart 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? |

178

[Q178 ]

Subpart OO | Are importers of HFCs required to obtain EPA approval before importing the HFCs into the U.S.? |

287

[Q287

Q287. 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?] | Subpart 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? |

292

[Q292

Q292. 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] |

Subpart 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? |

363

[Q363

Q363. 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?] | Subpart 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? |

364

Q364

Subpart OO

How do I calculate addition to the

"net supply"? |

365

[Q365

Q365. Why do net additions of GHGs have to be added manually when they already exist in the uploaded

forms?] | Subpart OO | Why do net additions of GHGs have to be added manually when they already exist in the uploaded |

366

Q366

Subpart 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)? |

390

Q390

Subpart OO | How do I report imports and exports of refrigerant blends that contain both HCFCs and HFCs? |

279

[Q279

Q279. To measure the composition of the CO2 stream, am I limited to the two methods listed in 40 CFR part

98.424(b)(2)?] | Subpart 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)? |