Q510. If company A owns and operates an underground storage facility but the associated storage wellheads are owned jointly by company A and company B but operated by company B, should the two companies submit separate emission reports?

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A510. Please refer to the definition of “facility” in 40 CFR 98.6.  According to this definition, there is only one facility, and only one report would be required.  Consistent with FAQ 51 , both company A and company B would be responsible for reporting, and the companies may choose among themselves who will submit the report for the facility.  The GHGRP provides owners and operators the flexibility to determine among themselves an appropriate Designated Representative (DR).  Please refer to the response to comment EPA-HQ-OAR-2009-0923-1024-16 regarding reporting by designated representatives (see pages 928-929 in https://www.regulations.gov/document?D=EPA-HQ-OAR-2009-0923-3608).

Updated on Jan 16, 2025