EPA proposes GHG reporting program

By Susanne Retka Schill
Large emitters of greenhouse gases (GHGs) will have to file their first annual GHG emissions reports with the U.S. EPA in 2011, if a new rule is adopted as proposed. EPA held about 100 meetings with more than 250 stakeholders, including trade associations, industries, environmental groups, and state and regional governments, during the development of the rule. Hearings were scheduled for April 6 and 7 in Washington, D.C., and April 16 in Sacramento, Calif. Written comments will be accepted for 60 days after the official publication of the proposed rule in the Federal Register. To read the text of the proposal and supporting information visit the Web site at

In general, the EPA proposed the new rule for suppliers of fossil fuels or industrial GHGs, manufacturers of vehicles and engines, and facilities that emit 25,000 metric tons or more of carbon dioxide equivalent per year. The GHGs covered by the proposed rule are carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride, and other fluorinated gases including nitrogen trifluoride and hydrofluorinated ethers.

The EPA estimated approximately 13,000 facilities will be covered under the rule, accounting for 85 percent to 90 percent of U.S. GHG emissions. The threshold is roughly equivalent to the annual GHG emissions from 4,500 passenger vehicles, 58,000 barrels of oil consumed or 131 railcars filled with coal. The vast majority of small businesses will fall well below the threshold and thus not be required to report. The EPA estimated that it will cost the private sector $160 million for the first year and $127 million in each subsequent year to comply with the new reporting requirement.

In most cases, the required data will come from the facility level, with a few exceptions where the reporting will be done at the corporate level. Among the exceptions are vehicle and engine manufacturers, fossil fuel importers and exporters, and local gas distribution companies. Under the EPA proposal, the first emissions report would be due on March 31, 2011, for emissions that occured during calendar year 2010. At that time, reporters would need to present total annual GHG emissions as an aggregate as well as separate emissions data for each source and supply category identified by the EPA. Fuel use and feedstock inputs used to generate emissions are to be reported, but not emissions from land-use changes or carbon storage.

EPA has published information sheets for each of the source categories covered in the proposed rule on its Web site under the resources link. In addition to manufacturers of chemicals and gases, the source categories include energy-intensive industries such as refineries, coal mines, electrical generation, cement production, electronics manufacturing, food processing and more. Emissions sources associated with agriculture, other than from certain very large manure management systems, are not covered by the rule.

The GHG reporting rule focuses on bottom-up data and individual GHG sources which will be used to inform decision makers as new policies are developed for GHG reductions. While the rule provides detailed data and will allow geographic analysis and industry analysis, it does not provide full coverage of total annual U.S. GHG emissions. The EPA will continue the annual Inventory of U.S. Greenhouse Gas Emissions and Sinks, which uses national energy data and other national statistics, to provide a comprehensive top-down national assessment of GHG emissions. The EPA has been tracking the national trend in emissions and sinks since 1990, submitting the report to the United Nations in accordance with the Framework Convention on Climate Change.