Q822. Part or all of my gathering and boosting operations reported stationary combustion emissions under Subpart C for RY2015. For RY2016, I am subject to Subpart W’s new Onshore Petroleum and Natural Gas Gathering and Boosting segment and I am required to report emissions at the basin level from gathering and boosting system sources not previously covered in my RY2015 report. Do I report my Subpart W basin emissions under the same facility registration that I used for my RY2015 Subpart C report? Do I continue to report combustion emissions under Subpart C?

A822. Gathering and boosting segment facilities that previously reported their stationary combustion emissions under Subpart C for RY2015 and previous years must report their stationary combustion emissions under Subpart W beginning in RY2016 (reports due March 31, 2017) and going forward.Beginning in 2016, facilities that meet the definition of the new Onshore Petroleum and Natural Gas Gathering and Boosting segment (aka “gathering and boosting”) in Subpart W will report emissions for all the source categories listed in 40 CFR 98.232(j).  This includes stationary and portable fuel combustion equipment emissions that may have previously been reported under Subpart C. 

Due to differences in the basin-level facility definition of a gathering and boosting facility as defined by 40 CFR 98.230(9) and the contiguous facility definition used for Subpart C as defined in 40 CFR 98.6, gathering and boosting facilities that previously reported stationary combustions emissions under Subpart C are encouraged to cease reporting for your previous Subpart C facility or facilities in e-GGRT and register a new facility (i.e. new e-GGRT ID) for the Subpart W Gathering and Boosting segment basin-level facility.  Reporters do not have to continue to submit annual reports after RY2015 for Subpart C facilities in this circumstance.

To assist facilities in this transition, EPA encourages previous Subpart C only facilities to notify the EPA of their intent to cease reporting for their previous Subpart C facility if they are intending to report stationary combustion emissions under Subpart W in the gathering and boosting segment after RY2015 reporting.  This notification may be updated at any time prior to RY2016 reporting and will prevent reporters from receiving future compliance notifications for Subpart C.

Fig 1:  Example of the Notification to Discontinue Reporting page in e-GGRT.  There is a specific notification checkbox for Subpart C facilities that will be reporting their stationary combustion emissions in Subpart W for RY2016.

If your company currently reports more than one Subpart C facility in a geologic basin, you should register a new facility in e-GGRT for Subpart W gathering and boosting operations that will include emissions for all of your previous Subpart C facilities in that basin. 

If your company currently reports only one Subpart C facility in a geologic basin, you may use your existing e-GGRT id to report your Subpart W emissions after RY2015; however, this may lead to confusion about your facility emissions trends.  You should be sure to amend the relevant information for RY2016 to cover all required source categories.