Final Change
The EPA Greenhouse Gas Mandatory Reporting Rule includes as many Specific Large Sources of GHG emissions as reasonably possible. However, studies show that a large percentage of GHG emissions come from the combustion of fossil fuels at relatively small facilities that may have boilers, process heaters, or other devices. Therefore, the EPA included a general category that covers all devices that combust fossil fuel. This general category can include any facility that uses fuel, and like other EPA reporting programs, it is the facility’s responsibility to determine whether they must report.

For the EPA’s fact sheet, click here:

BT² has evaluated the final rule and prepared the following summary to help you understand how this rule could affect your business.

Who Must Report?
According to the final rule, a facility must report if:

• Your facility’s maximum input rating is over 30 mmBtu/hr AND
• If your GHG emissions exceed 25,000 metric tons CO₂e/yr

To determine whether you would need to report as a Stationary Fuel Combustion Source under the final rule, add up the maximum input ratings listed on the nameplate of all your boilers, heaters, engines, and other devices that burn fuel. (See Chart below.) If your total maximum input rating is over 30 mmBTU/hr, then you must calculate your GHG emissions using one of four methods final in the EPA rule. If your emissions exceed 25,000 metric tons CO₂e/yr, you must report.

How are Emissions Calculated?
Emissions are calculated by multiplying the amount of energy that is in each fuel consumed by an emission factor corresponding to the specific GHG. That figure is then scaled by a Global Warming Potential Factor (GWP).

* HFC & PFCs: multiple compounds, each has unique GWP

The final rule has four emission calculation tiers, based on the facility size and fuel type burned. The EPA is using a maximum heat input capacity of 250 mmBTU/hr to distinguish between large and small facilities. Fuel with more variability, like coal, requires more testing to determine the emissions than natural gas.

For example, large facilities that burn coal and have existing continuous emission monitoring (CEM) equipment can calculate emissions under Tier 4. Other large facilities will use Tier 3 calculations, which rely on on-site fuel quality and consumption measurements. Smaller facilities burning gas and many types of liquid fuels would use monthly fuel consumption records (i.e., fuel bills) to calculate emissions with either Tier 2 or Tier 1 equations, depending on whether the heat content of the fuel was provided by the supplier. We have created a sample calculation of this system below for Tier 1.

Sample Calculation
There are many facilities that will exceed the 30 mmBtu/hr threshold, but will NOT exceed the 25,000 metric tons CO₂e/yr threshold. For your convenience, BT² has calculated fuel volumes that approximate the threshold of 25,000 metric tons CO₂ equivalent:

Reporting Requirements
As final, if your facility exceeds the thresholds described above, you will be required to report GHG emissions. You must begin collecting data on January 1, 2010, to support the first report due in early 2011. The report format itself has not yet been finalized. The report will be sent directly to the USEPA and must be certified by a responsible corporate official.

In most cases, the data needed to complete the report described above is most likely being collected currently by your facility. However, it is important to plan ahead and make sure that your current level of data collection is sufficient. For example, your fuel bill may include the quantity of fuel oil consumed, but may not include the heat content of the oil. Adding this level of detail to the fuel bill is an easy way to more accurately calculate GHG emissions from your facility.

Recordkeeping Requirements
In addition to the report itself, you will also need to document the procedures and calculations used to complete the report. You will need to identify key facility personnel and document recordkeeping and quality control procedures in a "monitoring plan" (Called a quality assurance performance plan (QAPP) in the proposed rule).

BT² can get you started by assisting in creating a GHG emissions inventory determining what equipment to include, documenting the proper emission factors and calculations, and providing you with written procedures and forms to capture the data you will need.

What about Mobile Sources?
The Mandatory Reporting Rule does NOT require facilities to include fuel combusted by Mobile Sources such as cars, trucks, airplanes, trains, and ships. Instead, this responsibility will lie with the engine manufacturers. The rule requires that manufacturers of certain engines add GHG emission rates to the other pollutants already reported for their engine designs, for example, hydrocarbons, nitrogen oxides, carbon monoxide and particulate matter.

The GHG reduction policy is already moving ahead on this front. On September 15, 2009 the EPA and DOE proposed a rule establishing a national program that would improve fuel efficiency and reduce Greenhouse gases.