Q50. When are reporters required to complete their GHG Monitoring Plan?
A50. Part 98 requires that all reporters subject to the rule have a monitoring plan in place. The purpose of the plan is to document the process and procedures for collecting and reviewing the data needed to estimate annual GHG emissions. Therefore, this plan needs to be in place prior to collecting data to ensure that consistent and accurate data are collected.
Additionally, the monitoring plan must include all of the elements listed in 40 CFR 98.3(g)(5)(i) of the rule. Per 98.3(g)(5) GHGRP reporters are required to maintain monitoring plans, but are not required to submit them using e-GGRT. Monitoring Plans are a record keeping requirement, not a reporting requirement.
Please contact us again if you have additional questions.