Topic Spotlight

Mandatory Greenhouse Gas Reporting Proposed

On April 10, 2009 (74 FR 16448-16731), EPA proposed regulations requiring the mandatory reporting of greenhouse gas emissions. In general, the proposed rule requires suppliers of fossil fuels and industrial gases, manufacturers of vehicles and engines, and individual facilities that emit >25,000 metric tons of carbon dioxide equivalent (CO2e) per year to submit annual emission reports. Under the proposed rule, the first emission report would be due March 31, 2011, and would cover emissions for calendar year 2010. Reporting requirements for motor vehicle and engine manufacturers would begin with the 2011 model year.

The proposed rule is expected to apply to more than 13,000 facilities, and would cover 85-90% of total U.S. greenhouse gas emissions. Annual greenhouse gas emission reporting would be required for CO2, methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF6), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and other fluorinated greenhouse gases. Annual emission reports would be submitted to EPA electronically. The designated representative of the entity submitting the report would certify that the report has been prepared according to the requirements of the proposed regulations.

EPA indicates that, for the government, the greatest benefit of mandatory reporting of industry greenhouse gas emissions would be realized in developing future greenhouse gas policies. According to the agency, the European Union's Emissions Trading System lacked accurate monitoring at the facility level before establishing CO2 allowance permits, which resulted in permit allocations that were, on average, 15% above actual emission levels in every country except the United Kingdom. Collecting consistent, quality assured emission data prior to, for example, enacting a U.S. cap-and-trade program, could lead to a more successful outcome.

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