EPA publishes Mandatory Reporting of Greenhouse Gas Emissions

On Tuesday, September 22, EPA Administrator Lisa Jackson signed the final rule for mandatory reporting of greenhouse gas (GHG) emissions. Record keeping requirements begin on January 1, 2010 and the first reports are due in 2011.

According to the EPA's website, "Under the rule, 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 are required to submit annual reports to EPA. The gases covered by the final rule are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFC), perfluorocarbons (PFC), sulfur hexafluoride (SF6), and other fluorinated gases including nitrogen trifluoride (NF3) and hydrofluorinated ethers (HFE)." EPA estimates that the rule covers 10,000 facilities and 85% of U.S. GHG emissions. For additional information, see: http://www.epa.gov/climatechange/emissions/ghgrulemaking.html

In it's revised form, the rule now excludes several specific source categories, including food processing, industrial landfills, and wastewater treatment. However, stationary fuel combustion sources are still subject to the 25,000 ton CO2 equivalent threshold. For manure management systems, the rule adds an animal population threshold to clarify applicability.

Next steps for businesses potentially affected by the rule include:

• Evaluating applicability of the rule to your facility
• Developing an inventory of GHG sources
• Determining how you will collect the required data beginning in January
• Installing additional monitoring equipment, if needed
• Calculating and reporting GHG emissions

If you need help with any of these steps, please contact John Hurtenbach (608-216-7365), Patti Stickney (608-216-7330), or your BT Squared project manager.

What can you do? Regardless of your industry type or local government unit, now is the time to develop an inventory of GHG sources and evaluate potential future costs and risks. For most facilities, GHG reduction will be achieved through energy assessment and conservation, which can be readily tied to other cost-saving initiatives such as waste minimization, lean manufacturing, and/or water conservation. There are several approaches to calculating GHG emissions. The final Mandatory Reporting Rule provides the basic calculations to benchmark your facility, so you will know where you stand in the low-carbon marketplace we are all entering.

BT2's Air Quality Team stands ready to help evaluate your emissions under the final rule and work with you to resolve any discrepancies.

Please contact John Hurtenbach, our GHG Lead, at 608.216.7365 or jhurtenbach@bt2inc.com for more information on how we can help. Watch for future updates on this important topic from BT Squared.