Greenhouse Gas Reporting Program (GHGRP) Subparts LL & MM Registration Guidance Document &EPA United States Environmental Protection Agency ------- Greenhouse Gas Reporting Program (GHGRP) Subparts LL & MM Registration Guidance Document Compliance and Innovative Strategies Division Office of Transportation and Air Quality U.S. Environmental Protection Agency &EPA United States Environmental Protection Agency EPA-420-B-11-004b July 2011 ------- Greenhouse Gas Reporting Program (GHGRP) Subparts LL & MM Registration Guidance Document UPDATED: July 14, 2011 In response to the FY2008 Consolidated Appropriations Act (H.R. 2764; Public Law 110-161), EPA has issued the Greenhouse Gas Reporting Program (GHGRP) under 40 CFR Part 98, which requires reporting of greenhouse gas (GHG) emissions from large sources and suppliers in the United States. Under Part 98, suppliers of fossil fuels or industrial GHGs, manufacturers of vehicles and engines, and facilities that emit 25,000 metric tons or more per year of GHG emissions are required to submit annual reports to EPA. Part 98 was published in the Federal Register (www.regulations.gov) on October 30, 2009 under Docket ID No. EPA-HQ-OAR-2008-0508- 2278 and became effective December 29, 2009. Subpart LL consists of producers, importers, and exporters of products listed in Table MM-lof Subpart MM that are coal-based (coal-to-liquid products). A producer of coal-to-liquid products is any owner or operator who converts coal into liquid products (e.g., gasoline, diesel) using the Fischer-Tropsch or an alternative process. Suppliers of coal-to-liquid products that meet the applicability criteria in the General Provisions (40 CFR 98.2) must report GHG emissions. Subpart MM consists of petroleum refineries and importers and exporters of petroleum products and natural gas liquids as listed in Table MM-1 of Subpart MM. A petroleum refinery for the purpose of Subpart MM is any facility engaged in producing petroleum products through the distillation of crude oil. This guidance document is intended to assist parties regulated under the GHGRP Subparts LL & MM register with Central Data Exchange (CDX) under OTAQReg. This document should be used in conjunction with the appropriate GHGRP registration web page (http://www.epa.gov/otaq/regs/fuels/fuelsregistration.htm) and the CDX User Guide (http://www.epa.gov/otaq/regs/fuels/420bl0022.pdf). For questions regarding the rule (40 CFR Part 98) or where you should register, please email GHGMRR@epa.gov or see the Greenhouse Gas Reporting Program web page. For questions regarding registration in CDX with the OTAQReg program or submitting reports using DCFuels, please email EPAFuelsPrograms@epa.gov. Companies may be required to register for BOTH e-GGRT and OTAQReg. Each user will only need one CDX user name which will log you in to both registration and reporting systems. The rest of this document will support registration for the three types of users under Subparts LL& MM: • First Time User o This user does NOT have an e-GGRT log-in. o This user does NOT have an existing CDX log-in. o This company is NOT registered with another Part 80 program • New User with Existing Company/Facility o This user does NOT have an e-GGRT log-in. o This user does NOT have an existing CDX log-in. o This company IS registered with another Part 80 program • Existing User o This user has EITHER an e-GGRT log-in OR existing CDX log-in. o This company may be registered with another Part 80 program Also included are templates for all supplemental documents required for registration. Please note all registration paperwork must be mailed to EPA in order to complete the registration process. • Appendix A: Digital Signature Agreement (DR/ADR/Agent) • Appendix B: CDX Submitter Delegation Letter (DR/ADR) UPDATED • Appendix C: Certificate of Representation (DR/ADR) • Appendix D: Agent Delegation Letter NEW • Appendix E: Agent Authorization Letter NEW • Appendix F: DR/ADR/Agent Company Authorization Form • Appendix G: DR/ADR/Agent Facility Authorization Form ------- Mail completed forms to: US Mail: U.S. Environmental Protection Agency Fuels Programs Registration (6406J) 1200 Pennsylvania Avenue, NW Washington, DC 20460 Commercial Delivery: U.S. Environmental Protection Agency Fuels Programs Registration Room 647C; 202-343-9038 1310 L Street, NW Washington, DC 20005 ------- First Time User These instructions should be used in conjunction with the First Time User instructions provided on the Fuels Programs Registration page. • This user does NOT have an e-GGRT log-in. • This user does NOT have an existing CDX log-in. • This company is NOT registered with another Part 80 program Supplemental Instructions: Step 5 Disregard bullet indicating "Office of Transportation and Air Quality EPA Moderated Transaction System (OTAQEMTS)" Step 9 The following are definitions for the initial user roles (clarified for GHGRP): • Submitter: Can submit reports on behalf of the company/facility, select if DR/ADR/Agent • Company Editor: Can edit and create registrations for the company/facility • Company Viewer: Can view company information, but not edit • Nominator: not applicable New company/facilities must be activated in CDX by EPA in order for additional users (DR/ADR/Agents) to associate with that company. Initial company registration should be completed by the DR who will submit a complete registration package. Once the company/facilities are activated by EPA, the ADR and Agent(s) can associate. Registration Package: 1. Create CDX and OTAQReg account, create new company and facilities (if applicable) 2. CDX New Registration Report 3. Digital Signature Agreement (Appx. A, DR/ADR/Agent) 4. CDX Submitter Delegation Letter (Appx. B, DR/ADR only) 5. Certificate of Representation (Appx. C, DR/ADR only) 6. Agent Delegation Letter (Appx. D, if applicable, signed by DR/ADR) 7. Agent Authorization Letter (Appx E, if applicable, signed by Agent) 8. DR/ADR/Agent Company Authorization Form (Appx. F), 1 per company 9. DR/ADR/Agent Facility Authorization Form, if applicable (Appx. G), 1 per facility All facilities, if applicable, can be registered in Step 1. Please note all registration paperwork must be mailed to EPA in order to complete the registration process. ------- New User with Existing Company These instructions should be used in conjunction with the New User with Existing Company instructions provided on the Fuels Programs Registration page. • This user does NOT have an e-GGRT log-in. • This user does NOT have an existing CDX log-in. • This company IS registered with another Part 80 program Supplemental Instructions: Step 12 The following are definitions for the initial user roles (clarified for GHGRP): • Submitter: Can submit reports on behalf of the company/facility, select if DR/ADR/Agent • Company Editor: Can edit and create registrations for the company • Company Viewer: Can view company information, but not edit • Nominator: not applicable Associating with a company for the first time will also associate you with all of its registered facilities (if applicable). You may not edit any part of the company and/or facility information until you have submitted the appropriate paperwork and it has been activated by EPA. Registration Package: 1. Create CDX and OTAQReg, associate with existing company (this will associate user with all facilities as well) 2. CDX New Registration Report 3. Digital Signature Agreement (Appx. A, DR/ADR/Agent) 4. CDX Submitter Delegation Letter (Appx. B, DR/ADR only) 5. Certificate of Representation (Appx. C, DR/ADR only) 6. Agent Delegation Letter (Appx. D, if applicable, signed by DR/ADR) 7. Agent Authorization Letter (Appx E, if applicable, signed by Agent) 8. DR/ADR/Agent Company Authorization Form (Appx. F), 1 per company 9. DR/ADR/Agent Facility Authorization Form, if applicable (Appx. G), 1 per facility If there are any facilities that are not currently registered, they can only be added after this information is submitted to EPA. Steps 5- 7 should reflect all facilities that are required to comply with Subparts LL and/or MM, even if they are not fully registered in CDX/OTAQReg. Please note all registration paperwork must be mailed to EPA in order to complete the registration process. ------- Existing Users These instructions should be used in conjunction with the Existing Users instructions provided on the Fuels Programs Registration page. • This user has EITHER an e-GGRT log-in OR existing CDX log-in. • This company IS registered with another Part 80 program Supplemental Instructions: Step 9 The following are definitions for the initial user roles (clarified for GHGRP): • Submitter: Can submit reports on behalf of the company/facility, select if DR/ADR/Agent • Company Editor: Can edit and create registrations for the company • Company Viewer: Can view company information, but not edit • Nominator: not applicable Registration Package: 1. If Company Editor, update and company and facility information as needed (in CDX/OTAQReg) 2. CDX Registration Report, if updates were made in CDX 3. Digital Signature Agreement (Appx. A, DR/ADR/Agent) 4. CDX Submitter Delegation Letter (Appx. B, DR/ADR only) 5. Certificate of Representation (Appx. C, DR/ADR only) 6. Agent Delegation Letter (Appx. D, if applicable, signed by DR/ADR) 7. Agent Authorization Letter (Appx E, if applicable, signed by Agent) 8. DR/ADR/Agent Company Authorization Form (Appx. F), 1 per company 9. DR/ADR/Agent Facility Authorization Form, if applicable (Appx. G), 1 per facility If there are any facilities that are not currently registered, they can be added in Step 1, if user has the company editor role. Steps 5-7 should reflect all facilities that are required to comply with Subparts LL and/or MM, even if they are not fully registered in CDX/OTAQReg. Please note all registration paperwork must be mailed to EPA in order to complete the registration process. ------- A complete registration package for a company and associated facilities (if applicable) will contain the following: 1. CDX New Registration Report (for new associations only) a. Required for EACH DR/ADR/Agent, that is new to OTAQReg 2. Digital Signature Agreement (Appx. A) a. Required for EACH DR/ADR/Agent that will submit reports i. if user does not currently have one in place for OTAQReg b. EACH signed by the appropriate DR/ADR/Agent 3. CDX Submitter Delegation Letter (Appx. B) a. Required for EACH DR/ADR b. Signed by the RCO c. Can have one letter that lists ALL DR/ADR names for one company and associated facilities 4. Certificate of Representation (COR) (Appx. C) a. Required for EACH DR/ADR b. Required for EACH facility, if DR/ADR is for multiple facilities, one COR is required for EACH c. EACH initialed and signed by appropriate DR/ADR 5. Agent Delegation Letter (Appx. D) a. Required for each Agent b. Signed by DR/ADR delegating authority 6. Agent Authorization Letter (Appx. E) a. Required for each Agent b. Signed by Agent accepting responsibility 7. DR/ADR/Agent Company Authorization Form (Appx. F) a. 1 template per company b. No signature required 8. DR/ADR/Agent Facility Authorization Form, if applicable (Appx. G) a. 1 template per facility b. No signature required ------- Appendix A: Digital Signature Agreement For users that will submit reports electronically on behalf of their company/facility. In accepting the electronic signature issued by the United States Environmental Protection Agency (EPA) to sign electronic documents submitted to EPA's Central Data Exchange (CDX), on behalf of: (Company Name) Address: City/State/Zip Code: Facility Name: I, (Name of the electronic signature holder) (1) Agree to protect the signature from use by anyone except me, and to confirm system security with third parties where necessary. Specifically, I agree to maintain the secrecy of the code where the signature is based on a secret code; (2) Understand that the Immediate Supervisor or Witnessing Official who signs below will be contacted by the US EPA and asked to validate my employment at the Corporation Name listed above; (3) Understand and agree that I will be held as legally bound, obligated, or responsible by my use of my electronic signature as I would be using my hand-written signature, and that legal action can be taken against me based on my use of my electronic signature in submitting an electronic document to the US EPA's CDX; (4) Agree never to delegate the use of my electronic signature or make my signature available for use by anyone else; (5) Understand that whenever I electronically sign and submit an electronic document to the US EPA's CDX, acknowledgments and a copy of my submissions will be made available to me; (6) Agree to review the acknowledgments and copies of documents I electronically sign and submit to the US EPA's CDX; (7) Agree to report to the US EPA, within twenty-four hours of discovery, any evidence of the loss, theft, or other compromise of any component of my electronic signature; (8) Agree to report to the US EPA, within twenty-four hours of discovery, any evidence of discrepancy between an electronic document I have signed and submitted and what the US EPA's CDX has received from me; (9) Agree to notify the US EPA if I cease to represent the regulated entity specified above as signatory of that organization's electronic submissions to the US EPA's CDX, as soon as this change in relationship occurs and to sign a surrender certification at that time. (EPA Program ID(s), e.g. Dun and Bradstreet Number) (Print Name) (Signature of electronic signature holder) (Date) (Official Title) ------- Appendix B: CDX Submitter Delegation Letter Required if DR/ADR is not the Responsible Corporate Officer. Printed on company letterhead. If you wish to submit reports to the EPA and you are not the Responsible Corporate Officer (RCO) or the owner of the company you have associated yourself with, your company must provide some additional information. EPA will accept reports that are signed by someone that the RCO or owner of a company has given that authority. These individuals must be employees of the company and must be familiar with the information being submitted. In order for EPA to accept reports under these circumstances, your company must do the following: • The owner or the RCO must compose a letter on company letterhead stating their title and their authority to delegate this responsibility. • This letter must name the individual who has the authority to make submissions on behalf of the company. • This letter must include a statement acknowledging that the RCO or owner (delegator) and their delegate(s) are responsible for the report information submitted by the delegate(s). • This letter must be signed by an RCO or owner. This must be a 'wet ink' original signature on letterhead. • This letter must be sent in attached to the printed, signed copy of this submission. You can find that document in .pdf form in your MyCDX Inbox. • Failure to include this letter will result in a delay of your registration and EPA will require you to resend the forms. CDX Submitter Delegation Letter To whom it may Concern: Please be advised that I «Responsible Corporate Officer Full Name», «Title», delegate «Delegate Full Name», «Title» » of «Com pany/Entity Name», Company ID «Company/Entity ID» to submit any and all information to the United States Environmental Protection Agency in relation to EPAs Fuels Programs. I authorize delegate «Delegate Full Name» to set up a Central Data Exchange (CDX) account and apply for and obtain an electronic signature enabling «him/her» to electronically sign and certify reports submitted to the EPA, on my behalf. «Delegate Full Name» understands the reports and information «He/She» is submitting. «Delegate Full Name» is my employee and is not a third party agent. I also establish «Delegate Full Name» to register for and use the following CDX applications on my company's behalf: Fuels Programs Registration Delegations [ ] OTAQReg: Fuels Programs Registration-Company Editor Role-Fuels Programs registration portal: My delegate may edit and electronically sendregistrations for my company. [ ] OTAQReg: Fuels Programs Registration-Company Viewer Role-Fuels Programs registration portal: My delegate may view my company registration information. Fuels Programs Report Submission Delegations [ ] OTAQDCFUEL: OTAQ DC FUEL Application-Submitter Role-The portal provides users the ability to electronically sign and submit encrypted reports over a secure connection. I understand I am granting my delegate the ability to send my reports via the portal, obtain an electronic signature and that they will have the Submitter role in the OTAQReg application for my company. The delegate will also have the ability to retrieve copies of the record that they submit. In addition, I acknowledge that I and the delegated person are responsible for the information submitted in accordance with the applicable subparts: [ ] Reports under 40 CFR Part 79 Subparts A, B, C, D, and F - Registration of Fuels and Fuel Additives [ ] Reports under 40 CFR Part 80 Subparts D, E, F, H, J, and L - Reformulated Gasoline / Anti-Dumping / Gasoline Toxics / Gasoline Sulfur/Gasoline Benzene [ ] Reports under 40 CFR Part 80 Subpart I - Motor Vehicle, Nonroad, Locomotive, and Marine Diesel Fuel [ ] Reports under 40 CFR Part 80 Subparts K and M - Renewable Fuel Standard [ ] Reports under 40 CFR Part 98 - Mandatory Green House Gas Reporting Renewable Fuel Standard Specific Delegations [ ] OTAQEMTS: OTAQ EMTS Application-Submitter Role-EPAs Moderated Transaction System (EMTS): EMTS is required for companies to generate and transact Renewable Identification Numbers for the Renewable Fuel Standard (RFS2). I understand I am granting my delegate the ability to perform all actions (including trades) for my company in EMTS and be assigned the Submitter role in the OTAQReg application. [ ] OTAQEMTS: OTAQ EMTS Application-Company Viewer Role-EPAs Moderated Transaction System (EMTS): EMTS is required for companies to generate and transact Renewable Identification Numbers for the Renewable Fuel Standard (RFS2). I understand I am granting my delegate the ability to view all actions for my company in EMTS and be assigned the Company Viewer role in the OTAQReg application. Obligated Party only Renewable Fuel Standard Specific Delegations [ ] OTAQWaiverCredits: Cellulosic Biofuel Waiver Credits Pay.gov Application-Company Submitter Role-Pay.gov portal: Pay.gov is used by obligated parties to purchase cellulosic biofuel waiver credits to be applied to a party's renewable volume obligation (RVO). In order to use this application, the user must know the amount of cellulosic biofuel waiver credits that the party needs. Additionally, a party may not purchase more credits than their party needs; nor may a party transfer credits to another party. This role is only applicable to refiners and importers of obligated volumes per the renewable fuel standard program. My delegate may purchase Cellulosic Biofuel Waiver Credits for my company through the OTAQWaiverCredits application in CDX. Signed, « Responsible Corporate Officer Wet Ink Signature» «Responsible Corporate Officer Full Name», «Title» «RCO email address» «RCO fax number» «RCO phone number» Date: «MM/DD/YYYY» Be aware that sending forms via US Mail will require an irradiation process and could possibly delay delivery. ------- Appendix C: Certificate of Representation Required for EACH DR/ADR for EACH company and/or facility. Printed on company letterhead. PR/ADR information: 1. Name of DR/ADR: 2. Address: 3. E-mail address: 4. Fax: 5. Name of company/facility (1 COR EACH): 6. List of owners/operators as required under 40 CFR 98.4(i)(3): "I certify that I was selected as the designated representative or alternate designated representative, as applicable, by an agreement binding on the owners and operators of the facility or supplier, as applicable." Initials DR/ADR: "I certify that I have all the necessary authority to carry out my duties and responsibilities under 40 CFR part 98 on behalf of the owners and operators of the facility or supplier, as applicable, and that each such owner and operator shall be fully bound by my representations, actions, inactions, or submissions." Initials DR/ADR: "I certify that the owners and operators of the facility or supplier, as applicable, shall be bound by any order issued to me by the Administrator or a court regarding the facility or supplier." Initials DR/ADR: "If there are multiple owners and operators of the facility or supplier, as applicable, I certify that I have given a written notice of my selection as the 'designated representative' or 'alternate designated representative', as applicable, and of the agreement by which I was selected to each owner and operator of the facility or supplier." Initials DR/ADR: DR/ADR Signature: Date: ------- Appendix D: Agent Delegation Letter Required for EACH Agent for EACH company and/or facility reporting under 40 CFR Part 98 Subpart LL and/or MM. Printed on company letterhead, signed by the Designated Representative (DR) or Alternate Designated Representative (ADR) that is delegating authority. Designated Representative or Alternate Designated Representative information: 1. Name of PR/ADR: 2. Address: 3. E-mail address (if any): 4. Telephone number: 5. Fax number (if any): Agent information: 1. Name of Agent: 2. Address: 3. E-mail address: 4. Telephone number: 5. Fax number (if any): 6. Company/facility name for which the submission will be made (1 Delegation letter for EACH): 7. Authority delegated for reports submitted under (select): a. 40 CFR Part 98 Subpart LL b. 40 CFR Part 98 Subpart MM Applications: Fuels Programs Registration Delegations [ ] OTAQReg: Fuels Programs Registration-Company Editor Role-Fuels Programs registration portal: My delegate may edit and electronically sendregistrations for my company. [ ] OTAQReg: Fuels Programs Registration-Company Viewer Role-Fuels Programs registration portal: My delegate may view my company registration information. Fuels Programs Report Submission Delegations [ ] OTAQDCFUEL: OTAQ DC FUEL Application-Submitter Role-The portal provides users the ability to electronically sign and submit encrypted reports over a secure connection. I understand I am granting my delegate the ability to send my reports via the portal, obtain an electronic signature and that they will have the Submitter role in the OTAQReg application for my company. The delegate will also have the ability to retrieve copies of the record that they submit. In addition, I acknowledge that I and the delegated person are responsible for the information submitted in accordance with the applicable subparts: [ j Reports under 40 CFR Part 98 - Mandatory Green House Gas Reporting "I agree that any electronic submission to the Administrator that is by an agent identified in this notice of delegation and of a type listed, and for a facility or supplier designated, for such agent in this notice of delegation and that is made when I am a designated representative or alternate designated representative, as applicable, and before this notice of delegation is superseded by another notice of delegation under 98.4(m)(3) shall be deemed to be an electronic submission certified, signed, and submitted by me." "Until this notice of delegation is superseded by a later signed notice of delegation under §98.4(m)(3), I agree to maintain an e-mail account and to notify the Administrator immediately of any change in my e-mail address unless all delegation of authority by me under §98.4(m) is terminated." DR/ADR Wet ink SignatureDR/ADR Full Name Date: «MM/DD/YYYY» ------- Appendix E: Agent Responsibility Letter The Agent Responsibility Letter must be submitted by individuals acting as Agents who have been delegated to submit reports for 40 CFR Part 98 Subparts LL and/or MM. Agent information: 1. Name of Agent: 2. Address: 3. E-mail address 4. Telephone number: 5. Fax number (if any): 6. Company/facility name for which the submission will be made (1 Delegation letter for EACH): I, «CDXSubmitter Name, Name ofCompany», understand that I will be submitting on behalf of «Name of Designated Representative or Alternate Designated Representative» and will only submit information that could be associated with the company/facility named above as true reportable information. I also understand any electronic submission to the Administrator signed by me shall be deemed to be an electronic submission certified, signed, and submitted by the Designated Representative or Alternate Designated Representative pursuant to 98.4(m)(3). Signed, «Agent's Wet ink Signature)) «Agent's Full Name» Date:«MM/DD/YYYY» ------- Appendix F: DR/ADR/Agent Company Authorization Form Required for each company required to submit reports under Subparts LL & MM. Printed on company letterhead. Ultimate Parent Company (highest- level and largest % owner per 98.3(c)(ll)) Company Name: EPA4-digitlD: NAICS Code(s): Street Address (no PO Boxes): City: State: Zip/Postal Code: Owner or Operator(s): Responsible Corporate Officer: First Name: Last Name: Phone: E-mail: re-type E-mail: Fax: Designated Representative (DR): First Name: Last Name: Phone: E-mail: re-type E-mail: Fax: Alternate DR (ADR): First Name: Last Name: Phone: E-mail: re-type E-mail: Fax: Agent (repeat as necessary): First Name: Last Name: Phone: E-mail: re-type E-mail: Fax: ------- Appendix G: PR/ADR/Agent Facility Authorization Form Required for each facility required to submit reports under Subparts LL & MM. Printed on company letterhead. Facility Name: EPA5-digitlD(s): Facility Registry System (FRS)#: Street Address (no PO Boxes): City: State: Zip/Postal Code: Owner or Operator(s): Designated Representative (DR): First Name: Last Name: Phone: E-mail: re-type E-mail: Fax: Alternate DR (ADR): First Name: Last Name: Phone: E-mail: re-type E-mail: Fax: Agent (repeat as necessary): First Name: Last Name: Phone: E-mail: re-type E-mail: Fax: ------- Additional Resources: Remove a User from CDX (Company Specific) User Association Termination Letter In order to remove an employee from a company's CDX registration, EPA requires a cover letter on company letterhead signed and dated by the Responsible Corporate Officer (RCO). The letter must instruct EPA to remove the employee's associations and lock the user's EMTS access. In the cover letter, the RCO must state; "I understand that the fuels programs will not contact CDX on my behalf and it is my responsibility to contact any other CDX application that the user uses or has used on my company's behalf." The letter must be mailed to either the USPS or commercial carrier address at the bottom of the page. Please remember, CDX accounts are individual based. The Fuels Programs will not lock a user's CDX account unless the user requests their account be locked. In the event a company feels the removal is an emergency (For example, immediate termination, compromised account, or the individual is no longer an employee of your company), the RCO must fax the letter to (202)343-2800, mail the letter to an address at the bottom of the page, and email EPAFuelsPrograms@epa.gov once the document has been faxed. The letter must be mailed on the same day as the request. The email subject should be "EMERGENCY EMPLOYEE REMOVAL" and the RCO must email EPAFuelsPrograms@epa.gov and include any applicable mail tracking number." Withdrawal from EPA Part 80 or 98 Fuels Programs Registration On company letterhead identify the entity name, company id and the Responsible Corporate Officer's name & title (if it has changed from that listed on the registration documentation, also include the prior RCO's name and the date when the change occurred). State the request to no longer be registered in « » EPA Fuels Program(s), that the entity no longer is conducting regulated business activities that require reporting, include the dates that regulated activities ceased, reports submitted [quarter, reporting year and report form names], and when any additional required documents [e.g. attest engagement] were or will be submitted. If applicable, also, include any change in ownership and their contact information. The Fuels Programs and their 40 CFR Subpart follow: Diesel 40 CFR Part 80, Subpart I Gasoline Sulfur 40 CFR Part 80, Subpart H Reformulated Gasoline & Anti-Dumping 40 CFR Part 80 Subparts D & E Renewable Fuel Standard 40 CFR Part 80, Subpart K & M Mandatory Green House Gas Reporting 40 CFR Part 98, Subpart LL Mandatory Green House Gas Reporting 40 CFR Part 98, Subpart MM ------- |