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Reminder of Upcoming Deadlines for Facilities Covered by EPA’s Greenhouse Gas Reporting Rule

The U.S. Environmental Protection Agency's (EPA's) “Mandatory Greenhouse Gas Reporting Rule” became final on December 28, 2009 and requires, beginning January 1, 2010, an estimated 10,000 facilities to monitor and electronically report annual greenhouse gas (GHG) emission data to EPA.  The rule applies to 29 industry categories as well as a general category of facilities not otherwise covered but that have fuel burning equipment (such as boilers or process heaters) that collectively exceed certain size thresholds.  The majority of covered facilities are subject to the rule’s monitoring and reporting requirements only where annual GHG emissions exceed 25,000 tons.  (A 10 million Btu/hour natural gas boiler, for example, emits an estimated 4,500 tons of carbon dioxide (one GHG) per year.)  Fifteen identified source categories must monitor and report regardless of GHG emission levels.

April 1 Deadline for the Installation of Monitoring Equipment

Depending on the applicable subpart, facilities subject to the GHG reporting rule may be required to install new or modified monitoring equipment.   Recognizing that not all sources may be able to procure and install new required monitoring equipment or complete calibration procedures by January 1, 2010, the rule allowed sources to use certain “best available monitoring methods” not meeting source category requirements, through the first quarter of calendar year 2010.  Absent written confirmation from EPA granting an extension of that deadline, facilities subject to the GHG reporting rule must have necessary monitoring equipment in place no later than April 1, 2010.   Requests for an extension of this deadline were required to have been submitted to EPA no later than January 28, 2010.

April 1 Deadline to have Monitoring Plans in Place

In addition to requiring tracking and reporting of GHG emissions, the GHG reporting rule also requires covered facilities to have in place a written monitoring plan that explains the processes and methods used to collect the data required by the rule, and the quality assurance, maintenance and repair procedures to be used for the required monitoring equipment. Under the rule, covered facilities are required to have monitoring plans in place no later than April 1, 2010.  The plan must be kept at the facility and must be made available to EPA upon request.

If you have questions regarding EPA's GHG reporting rule, please contact any member of Greenebaum’s Environment, Energy and Natural Resources Practice Group


Even though the content of the above Greenebaum Doll & McDonald e-bulletin is primarily informative, state and federal law obligates us to inform you that this is an advertisement. You have received this advisory because you are a client or friend of the firm.

 
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Greenebaum Doll & McDonald PLLC is a widely-respected business law firm with approximately 170 professionals in five offices, serving local, national and international clients in virtually every industry. A forward-thinking business law firm, Greenebaum is committed to the practice of Breakthrough Law®. For more information, visit www.greenebaum.com.

 

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