Q808. My facility has had ownership changes occur in the past few years. Who is responsible for reporting inputs to emissions equations that were deferred from reporting until 2015 for previous years?

A808. For reporting years 2010, 2011, 2012, and 2013, the deferred data elements were required to be measured or calculated and stored as records in those reporting years but were deferred for reporting until March 31, 2015.  As a result, facilities that were subject to the GHGRP in any of those reporting years must now report the deferred data elements.  To clarify who is responsible for reporting the deferred data elements in cases where ownership of part or all of a facility has changed hands since e-GGRT reporting began, the EPA provides the following example scenarios:

1. Entire Facility Ownership Changes: In general, when an entire e-GGRT facility changes ownership, the previous and current owners must update the Certificate of Representation (COR) and the Designated Representative (DR) per the requirements in 98.4(g) and (h) for the existing e-GGRT facility.  For such cases, the Designated Representative that is responsible for submitting that facility’s 2014 report by March 31, 2015 is also responsible for reporting any applicable deferred data elements for 2010, 2011, 2012, and 2013.   This includes the cases where an entire e-GGRT facility changes ownership to a new entity, which has not previously reported, or is merged with an existing e-GGRT facility (instead of simply continuing to report under the same e-GGRT ID).
   
   
2. Entire Facility No Longer Reporting: If a facility has ceased reporting in e-GGRT and was not merged with another facility, then the entity that owned the facility at the time it ceased reporting is responsible for submitting the deferred data for the years that facility reported to the EPA.
   
   
3. Transfer of Ownership for Individual Wells: Because of the unique nature of ownership of individual wells in  the Onshore Petroleum and Natural Gas Production segment of the Petroleum and Natural Gas Systems sector, if an entity has sold individual wells that were part of its e-GGRT facility to one or more different new owners (i.e., the e-GGRT facility was not transferred in its entirety to a new owner), then the entity which provided an annual GHG report to the EPA for those individual wells in a given reporting year is the entity which must report the deferred data for those individual wells for that year. For example, if an entity owned and reported information on 500 wells in a particular basin in 2011 but has since sold some of the wells and acquired others, then that entity is required to submit the deferred data elements associated with the emissions reported for the 500 wells for which emissions were reported in 2011. Because onshore wells are part of a basin-level GHG report and data for individual wells are not separately reported, the deferred data elements are not specific to individual wells.  Since these deferred data elements are not severable to the well-level, the deferred data elements associated with onshore wells must be reported for each year by the entity that submitted the annual report covering those wells for that specific year. This also ensures that the deferred data elements that are submitted by an entity for a given year are the data elements used to calculate the emissions reported in that year, thus allowing the EPA to verify the emissions data. This includes situations where all of the wells within a facility were sold to more than one new entity, because all of the individual wells did not transfer to the same new entity.  For situations where all of the wells within a facility were sold to only one entity, scenario #1 above applies.

These deferred data elements must also be reported for the 2014 reporting year (and in future years) by the Designated Representative that submits the annual GHG report for a given e-GGRT facility. The deferred data elements for reporting years 2010, 2011, 2012, 2013, and 2014 will be submitted to the EPA as part of the reporting year 2014 annual report.