September 2009 – Greenhouse Gas Emission Reporting

The Facts:The United States (U.S.) EPA has proposed a rule that requires mandatory reporting of greenhouse gas (GHG) emissions from large sources in the U.S.  In general, EPA proposes that suppliers of fossil fuels or industrial greenhouse gases, manufacturers of vehicles and engines, and facilities that emit 25,000 metric tons or more per year of GHG emissions submit annual reports to EPA.  The gases covered by the proposed rule are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFC), perfluorocarbons (PFC), sulfur hexafluoride (SF6), and other fluorinated gases include nitrogen trifluoride (NF3) and hydrofluorinated ethers (HFE).  EPA issued a Proposed Mandatory Greenhouse Gas Reporting Rule Fact Sheet at, which can be found at https://www.epa.gov/climatechange/emissions/downloads/ProposedRule-FactSheet.pdf  According to the fact sheet, 85 to 90 percent of total U.S. GHG emissions from approximately 13,000 facilities would be covered by the proposed rule.  Most small businesses would fall below the 25,000 metric ton threshold and would not be required to report GHG emissions to EPA.How will my company be affected?EPA is proposing that reporters would be required to submit their first GHG emissions report to EPA in early 2011. This report would provide data on emissions from the year 2010. EPA is proposing that reporting requirements for vehicle and engine manufacturers apply beginning with the 2011 model year.  EPA would be responsible for verification of data.  Mandatory third party verification was considered in the development of the proposed rule, but is not included in the proposed rule.  The GHG emissions inventories are likely to become the basis for regulation, pollution controls, and new emissions limits.The Proposed Mandatory Greenhouse Gas Reporting Rule public comment period ended June 9, 2009.  Late comments may be submitted on the proposed rule; however, the EPA is not required to consider comments submitted past the end of the official comment period when developing the final rule.  EHS Support will follow the issuance of the final rule, which is expected to occur in November 2009.There are states that are taking initiative on GHG reporting as well.  On December 6, 2007, the California Air Resources Board (ARB) approved Mandatory Reporting of Greenhouse Gas Emissions regulation.  Facilities had to submit data by June 1, 2009.  One difference from the proposed federal requirement is that the California regulation requires the mandatory reporting and verification of GHG emissions.  Facilities subject to reporting will be required to have their GHG emissions verified beginning in 2010 for their 2009 reported emissions.  Verification is optional for 2009 and 2008 reporting emissions. More information can be found at https://www.arb.ca.gov/cc/reporting/ghg-ver/ghg-ver.htmThe EPA tracks state planning and measurement efforts at https://www.epa.gov/climatechange/wycd/stateandlocalgov/state_planning.html#threeFor more information regarding GHG updates, please contact Amy Bauer of EHS Support at 251-533-5949 or amy.bauer@ehs-support.com

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