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Mandatory Federal Greenhouse Gas Reporting Under 40 CFR Part 98 To Begin in 2010
While Congress continues to debate the passage of a Greenhouse Gas (GHG) Cap and Trade bill, the USEPA has finalized and issued (on September 22, 2009) the Final Mandatory Reporting of Greenhouse Gases Rule as 40 CFR Part 98 that will require GHG reporting starting in calendar year 2011.
The final GHG reporting rule applies to facilities that emit more than 25,000 metric tons (27,588 short tons) of "carbon dioxide equivalents" (CO2-e) per year and to certain fuel suppliers, importers, or exporters. The rule applies to direct emissions only from stationary sources, and does not include rolling stock or electricity/indirect emissions. CO2-e includes carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), and certain fluorinated compounds, each of which have different global warming potentials (e.g., N2O as a GHG is 310 times more potent than CO2). These are gases that are not usually inventoried under current air quality operating permits.
It is vitally important to understand the "GHG footprint" of your operations to determine whether they will be subject to these reporting requirements. Further, understanding your facility’s emissions may be important to your business expansion decisions and the key to understanding the financial exposure associated with a possible need to obtain emission allowances, should a cap and trade program be enacted. From a planning perspective, potentially affected facilities should immediately develop a GHG inventory to estimate their current annual emissions and forecast future emissions to determine if they will be subject to the final rule and also determine the alternative scenarios that could require reporting.
For a more detailed analysis of the rule, click here or call Gavin Biebuyck at (610)375-9301 ext. 208
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