Compliance Briefing — March 15, 2024
Greenhouse Gas Reporting Program facilities have two weeks to certify 2023 emissions in e-GGRT, verify third-party QA, and document methodology updates before the March 31 deadline.
Executive briefing: EPA’s Greenhouse Gas Reporting Program (GHGRP) requires over 8,000 facilities, suppliers, and CO2 injection sites to submit verified 2023 emissions data by March 31, 2024. The e-GGRT portal is open for certification, and recent Part 98 amendments add methane emissions factors, renewable natural gas pathways, and leak detection provisions that must be reflected in this year’s reports.
Key compliance checkpoints
- Methodology updates. Subpart W operators must incorporate EPA’s November 2023 methane rule revisions, including new equipment leak factors and monitoring frequencies.
- Verification files. Upload XML data files, QA/QC checklists, and calibration records to e-GGRT and retain supporting calculations for at least three years per 40 CFR 98.3(g).
- Supplier obligations. Natural gas and petroleum product suppliers must reconcile sales volumes with emission factors to produce accurate emission equivalents.
Control alignment
- Integrate SCADA and historian feeds. Automate collection of throughput, flare volumes, and fuel characteristics into emissions calculation engines with change logs for audit trails.
- Cross-functional review. Coordinate environmental, tax, and sustainability teams so GHGRP submissions align with voluntary climate disclosures, SEC filings, and carbon pricing calculations.
- Exception tracking. Document missing data procedures and substitute values used under 40 CFR 98.35 to defend estimates during EPA audits.
Enablement moves
- Schedule mock EPA audit walkthroughs covering data flow diagrams, control owners, and remediation logs before certification.
- Update board or ESG committee dashboards with verified Scope 1 data and methane reduction progress relative to corporate targets.
- Prep investor relations talking points explaining variance drivers versus 2022 totals, including new production assets or abatement projects.
Sources
Zeph Tech connects e-GGRT workflows to operational telemetry, ensuring GHGRP submissions withstand EPA validation and investor due diligence.