September 29, 2009
EPA Finalizes Rule for Mandatory Emissions Reporting
by Robert Kropp
Facilities responsible for 85% of greenhouse gas emissions in the US will be required to monitor
and report on emissions starting in 2010.
Although the US was the world's largest producer of greenhouse gas (GHG) emissions until 2006 (when
it was surpassed by China), it has not distinguished itself in the international community for its
efforts at climate change mitigation. While it was a signatory to the Kyoto Protocol, its involvement in the
international agreement has been nonbinding, as neither President Clinton nor Bush submitted the
treaty to the US Senate for ratification.
In light of such a tradition of inaction,
last week's finalization by the US Environmental Protection
Agency (EPA) of a rule mandating the reporting of GHG emissions by approximately 10,000
facilities that account for 85% of total US emissions can be viewed as historic. The largest
emitting facilities will be required to submit annual reports to the EPA on their emissions
starting with calendar year 2010.
Five categories of emitters designated by the rule as
upstream sources will be required to report to the EPA. These sources include suppliers of
coal-based liquid fuels, petroleum products, natural gas, industrial GHGs, and carbon dioxide
(CO2). Among the 25 categories designated as downstream sources are electricity generation (which
accounts for 34% of GHG emissions in the US), petrochemical production, petroleum refineries, pulp
and paper manufacturing, and municipal sold waste landfills.
Vehicles and engines outside
of the light-duty sector will be required to begin phasing in GHG reporting with model year 2011.
According to the EPA, transportation accounted for 28% of GHG emissions in the US in 2007.
The reporting threshold established by the EPA is 25,000 metric tons of CO2 equivalent (CO2e)
per year. The threshold is equivalent to the annual GHG from the energy use of approximately 2,300
homes, or 4,600 passenger vehicles.
The EPA estimates the expected cost to the private
sector of complying with reporting requirements to be $115 million for the first year, and $72
million in subsequent years.
EPA Administrator Lisa P. Jackson said, "The American public,
and industry itself, will finally gain critically important knowledge and with this information we
can determine how best to reduce those emissions."