MRR Update: New Reporting Deadlines for 2012



The 2012 deadlines for submitting annual emissions reports under EPA’s Mandatory Reporting Rule for Greenhouse Gases (GHG) have changed again.  A facility’s 2012 annual report deadline is dictated according to which subparts apply to calendar year 2011 emissions.

The easiest way to determine the reporting deadline is to determine whether the facility is subject to any of the subparts that became newly effective in 2011.  If your facility is subject to any of the following new subparts, the reporting deadline for all applicable subparts automatically extends to September 28, 2012 (since September 30, 2012 falls on a Sunday).

New 2011 subparts are listed below:

  • Electronics Manufacturing (Subpart I)
  • Fluorinated Gas Production (Subpart L)
  • Magnesium Production (Subpart T)
  • Petroleum and Natural Gas Systems (Subpart W)
  • Use of Electric Transmission and Distribution Equipment (Subpart DD)
  • Underground Coal Mines (Subpart FF)
  • Industrial Wastewater Treatment (Subpart II)
  • Imports and Exports of Equipment Pre–charged with Fluorinated GHGs or Containing Fluorinated GHGs in Closed-cell Foams (Subpart QQ)
  • Geologic Sequestration of Carbon Dioxide (Subpart RR)
  • Manufacture of Electric Transmission and Distribution (Subpart SS)
  • Industrial Waste Landfills (Subpart TT)
  • Injection of Carbon Dioxide (Subpart UU)

If a facility must report by the 9/28/12 deadline, they must also log into e-GGRT and notify EPA they will not be submitting a report by 4/2/12 by selecting the appropriate check box in the “Not Submitting An Annual Report for 2011” section in e-GGRT.  See EPA’s presentation here for more details:  www.epa.gov/climatechange/emissions/downloads12/training/e-ggrt_RY2011_overview.pdf

If you are only reporting under the existing subparts that were effective in 2010, the reporting deadline is April 2, 2012 (since March 31, 2012 falls on a Saturday).

See the summary in Table 1 from EPA’s Fact Sheet covering the 2011 Special Provisions, available at www.epa.gov/climatechange/emissions/downloads11/documents/2011SpecialProvisions.pdf.

Table 2 provides example reporting scenarios that help to clarify the new deadlines based on subpart applicability.

For more detailed information, contact Aimee Andrews at aandrews@trinityconsultants.com.