If your company is intending to ask the EPA or an extension to use best available reporting methods (BAMM) under Sub Part W, that filing is due March 30th. You should have filed the NOI to do so by January 3rd in addition to having registered for the e-GGRT tool. A generic letter that you intend to use BAMM for reporting all sources from your well sites should be sufficient. However, be careful about wanting to use only the EPA tool for emissions reporting. I am hearing that BAMM formula is so expansive that almost everyone will be pulled into the 25,000 mt threshold. In fact, some operators have noted that as few as 14 wells in one basin will trigger reporting requirements. Also, the March 30th BAMM extension will only allow you to delay reporting to June 30th anyway.

If you did not file the NOI and therefore are not eligible for the BAMM extension, your company will need to file the whole application.

http://www.gpo.gov/fdsys/pkg/FR-2011-12-23/pdf/2011-31532.pdf Final rule SubPart A and W changes.

Also note that there will be an announcement on April 9th by the EPA as to which data elements reported under subpart W of Part 98 will be entities to confidential treatment under the Clean Air Act.