Energy and Carbon Management Blog

U.S. Businesses Await Release of Final EPA GHG Reporting Rule

Pace has learned through multiple channels that the long-awaited final EPA mandatory greenhouse gas (GHG) reporting rule is expected to be released this week.  This GHG reporting regulation will cover 85 - 90% of the nation's GHG emissions.  Facility-level reporting requirements will be triggered by specific industrial processes and/or stationary combustion emissions in excess of 25,000 metric tons of CO₂e. When the proposed GHG reporting rule was published in March 2009, U.S. businesses from a wide range of industry sectors were caught off guard by the complexity of data management, calculation, and record retention requirements

The proposed methodologies for calculating GHG emissions go well beyond the requirements of the leading voluntary reporting programs like The Climate Registry.  Impacted facilities will be expected to collect, manage, and report facility-level and unit-level details such as fuel carbon and high heat value results, monitoring and QA/QC records, and data collection and emission calculation methodologies.  Complicating the matter further, EPA established unique reporting methodologies for several industrial process emission sources (e.g. cement production, electric generation, petroleum refineries, food processing, electronics manufacturing, metals production, pulp and paper manufacturing, and others).

Now, with just over three months remaining in the year, it is apparent that affected U.S. companies will be challenged to prepare for this groundbreaking and complex regulatory requirement.  While Pace does not anticipate wholesale changes between the draft and final versions of the rule, EPA clearly solicited comments associated with several aspects of the rule.  These areas included, but were not limited to the following:

• Program schedule: EPA proposed options that would delay or relax 2010 data collection and reporting requirements in the event that the release schedule for the final rule does not allow sufficient time for entities to comply with methods described in the rule.
• Third party verification: Currently, reporters are expected to self-certify submittals and EPA would then perform audits of reports; EPA sought feedback on the need for third party verification.
• Scope 2 (purchased electricity) emissions: The draft rule does not require that facilities report indirect GHG emissions from electricity consumption, but EPA specifically asked for comments on this issue.

Even subtle changes in the rule could have significant implications to affected businesses.   Download a summary of the EPA rule and learn how Pace can help you address these complex challenges.