EPA's GHG Reporting Rule

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11 replies [Last post]
AASHE Member
Joined: Oct 29 2009

This is a topic that's been generating a lot of dicussion on the Green Schools listserv and I was hoping to continue it here where it can be saved for future reference.

I wrote an article for November's ACUPCC Implementer which summarizes the rule and includes links to the rule itself and resources for those that have to report. That article can be found in AASHE's blog and here if anyone is interested: EPA Signs Mandatory Reporting of Greenhouse Gases Rule. The main EPA page on the rulemaking is here: Final Mandatory Reporting of Greenhouse Gases Rule.

Coming up are some training webinars being sponsored by the EPA that people who think they may have to report might want to attend.

  • November 12, 2009, 1:00-3:00pm EDST - Question and Answer Webinar (This special session will be dedicated to question and answer with attendees.) (Register)
  • November 24, 2009, 3:30 – 5:30 pm EDST - Webinar (Register) (The EPA's Trainings site says, "This Webinar training session provides detailed information on such topics as applicability, estimating emissions, reporting, and recordkeeping requirements under the rule, as well as guidance for stationary fuel combustion facilities.")

There will also be one-day regional training sessions in Atlanta, Chicago, Dallas, and San Francisco - dates TBA.

gerry_1's picture
AASHE Member
Joined: Nov 23 2009

Brittany -

Thanks for your article - it was very well done.

Do you have a sense of what will be required to satisfy the EPA's guidance for reporting "All measured inputs used in the emissions calculations (e.g., fuel use, carbon content, heating value)"? Specifically, do you think that the "measured inputs" will need to be tracked by month and then reported by year?

Also, I subscribed to the Green Schools listserv today, but could you summarize the discussion on the EPA regs so far, for those of us who might have missed it?



AASHE Member
Joined: Oct 29 2009

Gerry, yes, I do think you'll want to track your inputs by month (just because that's probably the easiest way), calculate the amounts and types of emissions those would produce, and once a year combine those numbers and report them to the EPA through whatever reporting mechanism they develop. Remember, you only have to report if your school has a facility on campus that produces 25,000 metric tons CO2e per year. Some schools who haven't done any GHG inventories will have to measure for a few years anyway to determine if they do meet that threshold or not.

To summarize the Green Schools November ’09 discussion:
Carol Dollard in Facilities Mgmt at Colorado State U. began by bringing up some concerns. First, that the EPA’s reporting requirements were calendar-year based while the ACUPCC’s requirements were school-year or fiscal-year based. In fact, as Mike Lizotte, Director of Sustainability at the University of Wisconsin Oshkosh pointed out, the ACUPCC allows either fiscal year OR calendar-year reporting, but does ask that schools remain consistent either way. A few people who prefer calendar year reporting for the ACUPCC listed these reasons:

-- ACUPCC is listing reports by year (e.g. 2008), not school year (07-08 or 08-09?);
-- comparisons and integration with city, county, state, US, vendors, etc.
-- different fiscal year start/end dates (e.g. July 1 versus federal Oct 1)
-- The Climate Registry requires reporting by calendar year.  TCR is the closest thing that existed, previous to the EPA regs, to a national standard.  It's pretty consistent (or at least tries hard to be) with international standards, as well.  By moving toward a single standard, we can help promote inventories which are readily additive (that is, which can readily be summed by geographic area, by industrial sector, by whatever dimension is of interest) rather than difficult even to compare.

Carol was also concerned about the differences in which Scopes are required between the ACUPCC and the EPA’s regulation (Scope 1 only to EPA, Scopes 1,2, and 3 to the ACUPCC), and how that would affect ease of reporting and constituents’ perceptions of the two different numbers schools were putting out. She said, “These numbers will differ vastly and the difference will only be easy to explain to us "GHG nerds" that understand what Scopes are.  Any plans on ways to clarify these discrepancies for the folks who aren't as mired in this stuff as some of us?”

Rick Martin replied, “For protocols which are attempting to set up a comprehensive inventory scheme more than to educate, including only Scopes 1 and 2 makes sense -- Scope 1, because that's stuff you're burning yourself; Scope 2 because while the actual GHGs aren't being generated on your property, you have more control of demand levels than the utility companies do.

And for regulatory schemes (like the EPA regs), Scope 1 is where it's at.  (Remember, your Scope 2 emissions are the utility company's Scope 1.  Regulations focusing attention strictly on Scope 1 incent the utility companies to get cleaner which, in the longer term, will amplify any savings generated at the consumer end.)

My hope is that campuses will focus on the PCC number, and not be concerned if other numbers are reported to other agencies/repositories.  That way, differences can remain in the realm of GHG nerds like me.”

AASHE Member
Joined: Dec 23 2008

Does anyone know where Clean Air Cool Planet gets the emission factors used in the calculator?  I was checking them against the factors in the EPA rule and they seem to be different.  Also, the Global Warming Potentials for NOx and Methane are different.

Thanks for your help,

Heather Lair

University of Maryland

gerry_1's picture
AASHE Member
Joined: Nov 23 2009

Heather -

The CACP emission factors' sources are in the References worksheet, which is in the last three tabs or so.

For specific emission factors' sources, you can also look at the bottom of your column and see if there is a blue, underlined number. This is a link to the exact reference on the References tab.

Three things to note:

a) the EPA regulations cover specific "faciliites" and, for a school as large as Maryland, this definition is probably different than the whole school approach taken by CACP. This means that you will probably need to use something other than your CACP spreadsheet output to do your calculations for the EPA.

b) The EPA uses a per fuel "high heat value" (MMBTU per mass or MMBTU per volume) in its facility-level calculations (see Subpart C of 40 CFR 98), which CACP does not. This is a bit of a curve ball and means that you will need to determine your facilities' actual generation of MMBTUs.

c) The emission factors are different, and you would need to document to the EPA any reasons for not using their emission factors.

If you are looking to see if you meet the 25,000+ metric ton of CO2e criteria, my recommendation is that you will probably want to start your calculation from scratch using an annual summary of your facilities (using the EPA definition), get your high heat values, and use the EPA emission factors.

This isn't fun, but it may save you from getting sideways with the EPA!

Also, the EPA is having a school-specific Webinar on the new rules - here is what they say about it: "On February 10, EPA will conduct a specially tailored training session of the Mandatory Reporting of Greenhouse Gases Rule Webinar to address the informational needs of colleges and universities. All attendees are welcome; however, the session will focus on addressing questions submitted by academic institutions. To register and to view other training opportunities, please visit http://www.epa.gov/climatechange/emissions/training.html."

Hope this helps.

Gerry DeSeve



AASHE Member
Joined: Dec 23 2008

Thank you very much!  Most helpful.

Julian Dautremont-Smith's picture
StaffAASHE Member
Joined: Dec 16 2008

Hi Heather,

On the issue of global warming potentials, I suspect the difference is due to using figures from different versions of the IPCC's Assessment Reports. 

The IPCC's 1995 Second Assessment Report recommended 21 for methane and 310 for N2O over a 100 year time horizon.   In the IPCC's 2001 Third Assessment Report these figures were updated to 23 for CH4 and 296 for N2O.  Tthese numbers were updated again to 25 for CH4 and 298 for N2O in the 2007 Fourth Assessment Report, . 

I think many reporting programs have stuck with with Second Assessment Report GWPs because the changes aren't that significant and implementing new GWPs while ensuring consistency over time would be pretty complicated on the international level.  CACP has more flexibility and so has been updating its GWPs to the latest IPCC numbers.

I hope that helps,


Julian Dautremont-Smith
MBA/MS Candidate, Class of 2012
Erb Institute for Global Sustainable Enterprise
Stephen M. Ross School of Business | School of Natural Resources & Environment
University of Michigan

AASHE Member
Joined: Dec 23 2008

There is going to be a webinar specifically for colleges and universities on Feb 10 from 1 to 3 pm est.  Here is the info to register.  It's free. Go to https://www2.gotomeeting.com/register/543198147 for details.

gerry_1's picture
AASHE Member
Joined: Nov 23 2009

To help our existing and potential clients understand their reporting requirements under the Environmental Protection Agency's Mandatory Reporting of Greenhouse Gases Rule (MRR), we used our greenerApps GHG inventory system to create a complete greenhouse gas inventory for all stationary combustion units which reported on the Department of Energy's form EIA-860 in 2007. This was done using totals for fuel burned at a boiler level and the emission factors contained in the MRR.

We though it might be useful to anyone following this thread at AASHE.org to list the colleges and universities which reported their fuel use using the EIA_860, and who will likely need to report under the EPA MRR. We'll also cross post to Greenlist since some schools are not AASHE members or PCC signatories.

Here are their school and facility names, as well as the total equivalent carbon dioxide (ECO2 or CO2e) in metric tonnes (MT) for 2007:


Iowa State University: 368,245.06


Michigan State University: 654,982.31

Purdue University: 425,835.73

University of Alaska Fairbanks: 130,520.68

UCLA So Campus Central Chill Cogen Proj 140,312.17

University of Illinois Abbott Power Plt: 140,312.17

University of Iowa Main Power Plant: 290,127.52

Univ of Massachusetts Medical Center: 191,554.00

University of Michigan: 498,415.04

University of Missouri Columbia: 438,601.31

Univ of NC Chapel Hill Cogen Facility: 279,029.85

University of Notre Dame: 256,486.45

University of Oklahoma: 52,699.22

University of Texas at Austin, Hal C Weaver Power Plant: 212,446.84

Vanderbilt University Power Plant: 103,777.80

If your school reported on the EIA-860 but is not on this list, you are likely not going to be required to report, but - in any case - you should do a specific inventory for any large stationary combustion plants owned by your school.

Gerry DeSeve



t. (215) 965-7907

e. gerry (a) greenerapplications.com

w. www.greenerapps.com

Joined: Dec 16 2008

An update from the EPA:
EPA is announcing its intention to extend this year’s reporting deadline – originally March 31 – and plans to have the final uploading tool available this summer, with the data scheduled to be published later this year. This extension would allow EPA to further test the system that reporters will use to submit data, and give industry the opportunity to test the tool, provide feedback and have sufficient time to become familiar with it prior to reporting.

The agency will provide more detail on the intended changes in the coming weeks and will ensure that this reporting extension is in effect before the original reporting deadline of March 31, 2011.

Please check the GHGRP website for updates:

Joined: Dec 16 2008

Update from EPA
EPA has extended the deadline for reporting 2010 GHG data to September 30, 2011. This extension will allow EPA to further test the system that reporters will use to submit data, and give industry the opportunity to test the tool, provide feedback and have sufficient time to become familiar with it prior to reporting.

For more information go to: http://www.epa.gov/climatechange/emissions/extension.html

You can also view our press release.

Joined: Dec 16 2008

Update from EPA:

EPA’s Greenhouse Gas Reporting Program (GHGRP) is pleased to announce that registration is now open to stakeholders interested in an early look at the data reporting features of e-GGRT, EPA’s electronic Greenhouse Gas Reporting Tool.

Overview of the ‘sandbox’ testing period
In June 2011, stakeholders will have the opportunity to test e-GGRT in a ‘sandbox’ test environment. In this environment, testers will be able to enter test data in the reporting screens for the various subparts covered by the rule. Those who wish to test e-GGRT’s XML bulk upload capability may also test this feature in the sandbox.

To register for sandbox testing, please visit http://sandbox.ccdsupport.com. Please note that registered e-GGRT users must also register for the sandbox in order to participate in this testing period.

Sandbox testing terms and conditions
E-GGRT sandbox stakeholder testing is for authorized use only. Data in the sandbox system is NOT confidential and will not be protected as confidential. We recommend that you enter test data only. Data entered into the sandbox system will not be maintained by EPA and will not be accessible to the user once the testing period closes. All submitted information may be monitored, recorded, read, copied and disclosed by and to authorized personnel.

Webinar training
In advance of the sandbox testing period, EPA will hold a series of webinars to familiarize e-GGRT users with GHG reporting. The webinar schedule is below. You may register for these webinars at http://www.epa.gov/climatechange/emissions/training.html. We recommend that you register as soon as possible as space is limited.

May 5, 2011 2:00 PM EDT subparts C and D
May 9, 2011 12:00 PM EDT subparts C and D
May 9, 2011 2:00 PM EDT subpart S
May 10, 2011 12:00 PM EDT subparts X, Y, P
May 10, 2011 2:00 PM EDT subpart AA
May 11, 2011 12:00 PM EDT subpart NN
May 11, 2011 2:00 PM EDT subpart HH
May 11, 2011 4:00 PM EDT subpart Q
May 12, 2011 1:00 PM EDT subpart H
May 12, 2011 3:00 PM EDT subpart N
May 16, 2011 11:00 AM EDT subpart OO
May 26, 2011 2:00 PM EDT subparts C and D
May 31, 2011 11:00 AM EDT subparts C and D

We look forward to your participation in the e-GGRT sandbox testing effort!



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