Beveridge & Diamond
Related Practices
Related Practices

January 30th Deadline Approaching for Companies That Must Register for GHG Reporting

Beveridge & Diamond, P.C., January 20, 2011

A registration deadline is fast approaching for companies subject to the federal Greenhouse Gas Reporting Program, 40 CFR Part 98.  Under Part 98, designated representatives, those who are responsible under the rule for certifying, signing and submitting annual greenhouse gas (“GHG”) reports, must be registered sixty days prior to the March 31, 2011 deadline for submitting the first annual GHG report.  Certificates of registration must therefore be provided to the Environmental Protection Agency (“EPA”) by no later than January 30, 2011. Further, the agency is requiring designated representatives to submit hard copies of electronic signature agreements by mail prior to registering, and is strongly encouraging parties to mail these agreements to EPA by January 20, 2011. Certificates must be processed by EPA before the electronic registration process can be completed.

There are two methods for registering a designated representative, depending upon the subparts of 40 CFR Part 98 that apply to a GHG reporter.  The majority of facilities and suppliers regulated by the Greenhouse Gas Reporting Program will register through the online Electronic Greenhouse Gas Reporting Tool (“e-GGRT”) system, available at Companies that have existing Central Data Exchange (“CDX”) Web accounts can use their CDX user names and passwords to access the e-GGRT system.  New e-GGRT users must complete a user registration and submit a hard copy of an electronic signature agreement to EPA by mail. After EPA reviews the electronic signature agreement and grants acces to the system, users must complete the facility/supplier registration, identify a designated representative, identify agents, if desired, and sign and submit the certificate of representation and notice of delegation to EPA. 

Those suppliers who must report under subpart LL, suppliers of coal-based liquid fuels, and subpart MM, suppliers of petroleum products, will register through a different system, EPA’s CDX program. EPA has just issued registration guidance for those suppliers, which is available at and The guidance outlines different steps that must be taken by the designated representatives for these suppliers, depending upon whether the companies are first time users, new users with existing registrations under EPA’s fuels registration program (40 CFR Part 80), or existing users with current e-GGRT or CDX access.

For further information on the GHG reporting rule or on the registration process, please contact Stephen Richmond at, or Aladdine Joroff at