EPA Reporting Rules and how it may affect you

Many businesses and municipalities may be required to track their greenhouse gas (GHG) emissions in 2010. Entities that are affected need to prepare for this regulation which is still evolving. Here is an outline of the current EPA GHG rule:

  • Mandatory comprehensive GHG reporting for 10,000+ US facilities
  • Currently affects activities resulting in direct GHG emissions of over 25,000 tons per year (equivalent of powering ca. 2,200 homes)
  • Rule requires certain entities to provide a detailed monitoring plan
  • First annual monitoring report due March 1st, 2010
  • About 17 states have their own GHG reporting rules (EPA rule does not preempt states)
Background:
In September 2009 the EPA Administrator established a new federal requirement that mandates greenhouse gas (GHG) reporting for about 10,000 US facilities initially. The rule went into effect on January 1, 2010 and applies to large greenhouse gas emitters such as suppliers of fossil fuels or industrial GHGs, manufacturers of vehicles and engines, and facilities that directly emit 25,000 metric tons or more of GHG emissions per year (Figure 1). Most of the large manufacturers and some others (e.g. landfill operators) have to report GHG whether or not they exceed the threshold. Specifically included are:
  • Direct combustion equipment units, such as boilers, combustion turbines, engines, incinerators, and process heaters;
  • Fuel refiners, gas processors, natural gas distributors, coal mines, and importers;
  • Manufacturers and processors of iron, steel, aluminum, pulp and paper, chemicals, and industrial gases;
  • Manufacturers of mobile sources;
  • Agriculture and waste management, including landfills, wastewater treatment, ethanol production, manure management, and food processing.
Indirect emissions such as electricity are not required to be reported yet. The rule was issued in order to establish a nationwide mandatory reporting system. Emissions are reported for each individual facility. Facility means any physical property, plant, building, structure, source, or stationary equipment located on one or more contiguous or adjacent properties

Overall, approximately 85% of the total US emissions will be covered under the rule. The greenhouse gases covered under this rule include carbon dioxide (CO2), nitrous oxide (N2O), methane (CH4), hydrofluorocarbon (HFCs), perfluorocarbon (PFCs) and sulfur hexafluoride (SF6).

First monitoring reports will be due on March 1st, 2010. The rule allows for one designated representative per facility. Annual GHG reporting also requires facilities to have in place a detailed and comprehensive monitoring plan that needs to follow the code of federal regulations. Generally, reporting is different from existing GHG reporting protocols such as issued by the Carbon Disclosure Project, The Climate Registry and other organizations. Reported emissions will be verified by the EPA who will facilitate electronic reporting in the future.

Figure
Figure 1: Facilities covered under the EPA GHG reporting rule.