New EPA Greenhouse Gas Report Rule In Effect
in
December 14, 2009
Monitoring Requirements Begin January, 2010;
Monitoring Plans Due By April 1, 2010
On September 22, 2009, the U.S. Environmental Protection Agency (EPA) issued a final rule for mandatory reporting of greenhouse gases (GHG). The immediate question for many facilities is whether they are large enough emitters of GHGs to be covered by the new reporting rule. If so, they will need to begin collecting, analyzing and reporting data on GHG emissions by January 1, 2010. EPA estimates that approximately 10,000 facilities, representing 85% of all GHG emissions in the U.S., are covered by the reporting rule.
The list of specifically affected sources includes energy intensive industries, such as:
- power plants
- pulp and paper mills
- aluminum production facilities
- iron and steel mills
- petroleum refineries
- cement kilns
However, the rule also applies to miscellaneous stationary combustion sources having actual GHG emissions of 25,000 metric tons or more. This will result in some moderate GHG sources (large hospitals, universities and office complexes, etc.) being required to collect data on stationary fuel combustion, and to follow specified procedures for quality assurance, missing data, recordkeeping and GHG reporting. As a general guide, you should evaluate rule applicability if your facility has combustion sources with combined heat inputs of 30 million Btu’s per hour (MMBtu/hr) or greater.
The final rule requires annual reporting for calendar year 2010 emissions, with the first reports due from affected facilities by March 31, 2011. Formal monitoring plans must be completed by April 1, 2010.
Facilities that determine they are covered by the rule, may want to carefully examine their emissions estimates, especially if their initial calculations reveal that they are near the reporting threshold of 25,000 metric tons. If rule coverage is unavoidable, a facility may benefit from considering strategies for exiting the reporting program. They would be able to exit the reporting program if they reduce facility-wide GHG emissions, in any of the following ways:
- 5 consecutive years of emissions below 25,000 metric tons GHG/year, or
- 3 consecutive years of emissions below 15,000 metric tons GHG/year, or
- Shut down of GHG-emitting processes or operations.
Additional information redarding the new Greenhouse Gas Report rule is provided in the October 12, 2009 Environmental Review Newsletter.
Contact Roux
Roux Associates’ air quality compliance and climate change professionals (including DOMANI, a wholly owned subsidiary of Roux Associates, Inc.) have extensive experience with emissions estimation, measurement, reporting, and GHG reduction and strategy development. Our previous engagements have been with a wide range of clients, including the following representative GHG/Climate change client list:
Allstate
Cisco
Dean Foods
Del Monte
Estee Lauder
Exxon Mobil
Gerdau Ammeristeel
Hunter Douglas
IEPA
Invensys
McGraw-Hill
National Geographic Society
Pepco Holdings
Pfizer
Schering Plough
State of Illinois
State of New Mexico
The Coca-Cola Company
United Airlines
William Wrigley Jr. Co.
Should you have any immediate questions regarding this memorandum, or if you would like to explore how we can help you evaluate rule applicability, or comply with rule requirements, please feel free to contact Paul Eisen, CCM, Principal Scientist at Roux Associates, at peisen@rouxinc.com or (631) 232-2600.
Notice: ENVIRONMENTAL REVIEW is published by Roux Associates Inc., Islandia, New York. The information contained herein is provided for educational and informational purposes only and should not be taken as technical consulting advice for specific situations, which depends on an evaluation of site-specific factual information. Please direct questions or comments to the Roux Associates professional named in a specific article. Copyright Roux Associates, Inc., 2009.