Appendix E
Calculation Methods Appendix Part I
This appendix details the Commission’s methodology to calculate the emissions intensities of covered steel and aluminum produced in the United States by product category in 2022. To reach this set of estimates, the Commission calculated facility-level scope 1, 2, and 3 emissions within the system boundaries described in chapter 2. The Commission then allocated facility-level emissions to the facility’s production processes, at which point they were then used to estimate product-level emissions inventoriesthe emissions associated with product themselves. Emissions intensities were calculated by dividing each product’s emissions inventory by production output of that product.
The Trade Representative’s letter specified many of the data collection methods and data sources to be used in this investigation as well as coverage in terms of the scope of emissions, product categories, and materials to be considered. In order to fulfill the elements of this request, the Commission reviewed existing standards and frameworks for GHG emissions accounting. This review provided the Commission with an understanding of the existing approaches for emissions accounting. The Commission then created an outline for its own methodology, generally following these accepted approaches within the confines of the data available and with an understanding of the end use for these measures (i.e., to inform international trade policy).480F[477] The Commission sought feedback on its proposed calculation methodology throughout the investigation via interviews, site visits, public hearing testimony, and investigation record submissions from industry, nongovernmental organizations, labor groups, U.S government agencies, think tanks, and academia. After receiving this feedback, the Commission worked to incorporate pertinent comments into its approach and continued to refine its methods based on further desk research on available data sources.
As mentioned in chapter 1 (“Guiding Principles for This Investigation”), the Commission strove to satisfy several guiding principles in the development of its methodology. In particular, the methodology was designed to achieve the principle of completeness, with consistent collection of the same set of emissions across all facilities within broad system boundaries. In addition, the methodology sought to maximize interoperability with existing data sources and government frameworks for emissions accounting. This orientation of the methodology in turn informed the development of the data collection strategy, which was designed around acquiring the level of precision needed to deliver measures responsive to trade policy while minimizing the reporting burden on the respondent and protecting confidential business information.
This appendix contains the detailed data sources and calculations for each step of the Commission’s methodology, following the high-level descriptions in chapter 3. The appendix then provides an overview comparison of the different standards and frameworks the Commission consulted in the creation of its own methodology. The appendix closes with a tabular review of the data sources that the Commission used to develop and verify its emissions intensity estimates.
I. Overview of Product-Level Emissions Intensity and Inventory Calculations
For all product categories ( ), the Commission calculated emissions intensities ( ) by dividing the product-level emissions inventory ( ) by production of that product ( ) (equation E.1). This approach was taken both for the industry-wide emissions intensities presented in this report and for the emissions intensities of products made by individual facilities.481F[478]
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includes the totality of emissions that occur during all processes within the system boundary that produceor supply energy to the production ofthe product category. The Commission developed a uniform approach to calculating for “reference products,” a defined set of mutually exclusive product categories that include all covered steel and aluminum products and other upstream materials made by facilities producing covered products within the system boundaries of this investigation (see table E.1). These “reference products” are denoted throughout this appendix’s equations with the subscript.482F[479] For each reference product, was calculated using equation E.2.
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refers to the “unit process emissions” directly attributed to the discrete production process (the “unit process”) that makes the reference product and is calculated using equation E.3.
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Scope 1 process emissions ( ) and scope 1 fuel combustion emissions ( ) are the direct emissions that occur in the unit process itself. Scope 2 emissions ( ) and scope 3 emissions ( ) are indirect emissions associated with the unit process due to that production process’s direct use of purchased energy and material inputs.
The following sections of this appendix covering process emissions, energy-related emissions, and scope 3 emissions provide greater detail on how the Commission calculated each of these scope-specific unit process emissions terms. All these approaches, however, use the same process subdivision and physical allocation principles described in chapter 3 (“Allocation of Facility-Level Emissions to Unit Processes”), in particular, the allocation of facility-level emissions to “subprocesses.” Subprocesses are defined facility processes for which facilities provided input and output data within the questionnaire and that correspond with emissions data reported under the GHGRP program.483F[480] Some subprocesses produce only a single reference product, in which case subprocess-level emissions serve without modification as unit process emissions for that reference product. Other subprocesses correspond with two or more reference products, in which case subprocess-level emissions are further allocated to the multiple unit processes corresponding with those reference products using physical allocation.484F[481] The list of subprocesses and corresponding reference products used in this investigation is provided in table E.1.
Table E.1 List of facility subprocesses and corresponding reference products
Subprocess |
Corresponding reference products |
Anode baking for primary unwrought aluminum production |
Carbon anodes |
Smelting of primary unwrought aluminum |
Primary unwrought aluminum |
Casting of primary unwrought aluminum |
Primary unwrought aluminum |
Secondary unwrought aluminum production |
Secondary unwrought aluminum |
Wrought aluminum production |
Bars, rods, and profiles; plates, sheet, and strip; foil; wire; tubes, pipes, and tube or pipe fittings; castings; forgings |
Lime and dolime production |
Calcined lime; calcined dolime |
Production of oxygen, nitrogen, argon, or hydrogen |
Oxygen; nitrogen; argon; hydrogen |
Metallurgical coke production (e.g., in a coke oven or coke battery) |
Metallurgical coke |
Iron sinter production |
Iron sinter |
Liquid pig iron production in a rotary hearth furnace |
Pig iron |
Blast furnace operations, including pig iron casting |
Pig iron |
Steelmaking, including BOF or EAF operations, preheating ferrous scrap, refining/ladle station, decarburization, and casting |
Semifinished steel (carbon and alloy, stainless) |
Remelting and further working of previously cast semifinished steel into different forms of semifinished steel (e.g., electroslag remelting, vacuum arc remelting) |
Semifinished steel (carbon and alloy, stainless) |
Hot-rolling flat steel products |
Hot-rolled flat steel products (carbon and alloy, stainless) |
Cold-rolling flat steel products |
Cold-rolled flat steel products (carbon and alloy, stainless) |
Production of seamless tubular products |
Seamless steel tubular products (carbon and alloy, stainless) |
Production of non-seamless tubular products |
Non-seamless steel tubular products (carbon and alloy, stainless) |
Hot-working long steel products |
Hot-worked long steel products (carbon and alloy, stainless) |
Cold-forming or cold finishing long steel products |
Cold-formed long steel products (carbon and alloy, stainless) |
Coating, cladding, or plating flat steel products |
Carbon and alloy coated flat steel products |
Ambient heating, cooling, ventilation, and lighting supply in facilities where production occurs, if measured separately from the process-specific fuel use reported above |
All |
Processes used to make products other than covered steel, covered aluminum, or their upstream material inputs |
None |
Activities of other producers operating on-site |
None |
Stationary equipment that shreds or sorts scrap |
None |
Ancillary (non-production) activities that are not associated with production floor operations |
None |
Source: Compiled by the USITC.
Note: Each reference product made by a subprocess has a corresponding unit process (i.e., the unit process is the specific process covering the production of the reference product). Emissions associated with subprocesses that correspond to no reference products are out of the Commission’s system boundary and are not allocated to any product-level inventories. The emissions associated with ambient heating, cooling, ventilation, and lighting supply are allocated to any reference products and any noncovered production using the physical allocation approach. The term “carbon and alloy, stainless” indicates that the subprocess makes stainless steel and carbon and alloy steel versions of that product type.
In addition to unit process emissions, equation E.2 includes the contributed emissions from upstream processes in the facility that do not directly produce the reference product but are still included in the product-level emissions inventory, captured in . Specifically, is the inventory of emissions associated with a quantity of a material ( ) that is made in the same facility and used in the production of the reference product. This term is summed across all materials made in the same facility that feed into production of the reference product. The methods for calculating are described below (“Computing Product-Level Emission Inventories”).
[477] Data availability was in large part determined by the development and execution of the Commission’s data collection plan, which was developed in parallel with the Commission’s methodology. A draft of this proposed calculation methodology was released alongside the Commission’s draft questionnaires during the public comment period for the data collection plan to be reviewed by the Office of Management and Budget. For more information on the Commission’s data collection, see appendix H (“Data Collection”).
[478] Emissions intensity estimates for products made by individual facilities are used predominantly in two parts of the methodology. In the scope 3 analysis, they are sometimes used as emissions factors for other consuming facilities that received products from other facilities. In the calculation of industry-wide “highest” emissions intensity values, the emissions intensity values from individual facilities are used to determine each facility’s position within the industry’s distribution. The industry-wide highest emissions intensity is the average emissions intensity of the facilities with the highest emissions intensities that comprised 10 percent of the production of a product category or subcategory, unless otherwise noted. Once the emissions intensity estimates are computed at the facility level for each product category or subcategory, facilities are arranged in descending order of the emissions intensities, and cumulative production shares are calculated. Facilities are included until 10 percent of cumulative production is captured from the top end of the emissions intensity distribution. Finally, average emissions intensity is calculated using the same formula as the average national emissions intensity calculation in E.1 above. More information regarding the average and highest computation can be found in appendix H (“Computational Methods”).
[479] Certain product categories that are either more or less granular than reference products require different approaches to calculating product-level emissions inventories. These include aggregate product categories (wrought and unwrought aluminum, and flat, long, tubular, and stainless steel). These also include several subcategories of steel product categories. The methods for calculating the product-level emissions inventories of these products are described in a later section of this appendix (“Additional Analysis for Aggregate Product Categories and Product Subcategories”).
[480] EPA, “GHGRP, Envirofacts GHG Query Builder,” accessed September 18, 2024.
[481] All unit processes contain at least one subprocess related directly to the production of a reference product in addition to the subprocess “ambient heating, cooling, ventilation, and lighting supply,” which is split using physical allocation across all production at a facility. In some cases, several subprocesses contribute to the same unit process. For example, both the “smelting of primary unwrought aluminum” and the “casting of primary unwrought aluminum” subprocesses contribute to the production of primary unwrought aluminum (a unit process). If a facility had emissions under multiple subprocesses contributing to the same unit process, then corresponding unit process emissions are aggregated. For example, if a facility had scope 1 fuel combustion emissions associated with both smelting and casting of unwrought aluminum, these would both be assigned to the production of primary unwrought aluminum and added together.