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?

A285.  If both the direct emitter (source categories in Tables A-3 or A-4) and supplier (source categories in Table A-5) operations have the same designated representative and are in the same physical location, you may be able, but are not required, to register once in e-GGRT for both the direct emitter and supply operations. Further, you may be able, but are not required, to submit one annual GHG report containing information for both your direct emitter and supplier operations. Because importers and exporters report at the corporate level rather than at the facility level, importers and exporters must register and report separately.

In order to complete one registration for both direct emitter and supplier source categories, a single designated representative for both sets of operations must complete the Certificate of Representation submission process in e-GGRT. Additional information on using e-GGRT to complete facility registration can be found here: http://www.ccdsupport.com/confluence/display/help/About+Facility+Registration

One Certificate of Representation would be submitted that applies to both the direct-emitter and supply operations (see 98.3(c)(9)). Further, in order to submit one Certificate of Representation, and subsequently one annual GHG report (covering both direct-emitter and supply operations), the general information reported in 98.3(c) must be the same for both your direct emitter and supply operations. If these criteria are met, you may register your entity once in e-GGRT and submit one annual GHG report including both your direct emitter and supply operations.

If the direct emitter and supplier have different designated representatives, or if you will report different information under 98.3 (c) for the direct emitter and supply operations, then you must register and report for your direct emitter and supply operations separately.

Please note that reporters subject to Subpart LL (Suppliers of Coal-based Liquid Fuels) and/or Subpart MM (Supplier of Petroleum Products) reported in conjunction with EPA's Office of Transportation and Air Quality (OTAQ) using the DCFUEL application for reporting years (RY) 2010 and 2011. Starting on January 26, 2013 subpart LL and MM reports (both RY2012 submissions as well as revisions to RY2010 or RY2011) will be submitted using the electronic Greenhouse Gas Reporting Tool (e-GGRT). For additional information regarding the transition from DCFUELS to e-GGRT please refer to the Subpart LL and Subpart MM Transition to Reporting using e-GGRT factsheet.