November 2009 – Mandatory Reporting of Greenhouse Gases Effective 12/29/09: Where to Begin?

Following our September 29, 2009, client alert entitled “Mandatory Reporting of Greenhouse Gases Now a Reality”, EHS Support has received several requests from our clients for more information and assistance with meeting the requirements of the new rule. Two major developments have occurred since our September 2009 client alert was issued:

  • On October 30, 2009, U.S. Environmental Protection Agency (EPA) published the final rule in the Federal Register, “Mandatory Reporting of Greenhouse Gases; Final Rule” (GHG Mandatory Reporting Rule) (Volume 74, Number 209).  The final rule becomes effective on December 29, 2009.  Affected facilities must begin collecting greenhouse gas (GHG) emission data on January 1, 2010, with a report to be generated by March 31, 2011 for reporting year 2010.
  • EHS Support has conducted several high-level reviews of the potential GHG emissions from companies with stationary fuel combustion sources to determine if their facilities were subject to reporting under the GHG Mandatory Reporting Rule.  We completed these reviews utilizing facility-specific information about fuel consumption and GHG emission sources.

A high-level review, such as the one described above, is a cost-effective way to get a jump start on the GHG Mandatory Reporting Rule.  It provides a company with a means to estimate both capital and environmental budgets for 2010/2011 by determining if they are potentially subject to the GHG Mandatory Reporting Rule.  The high-level review also gives companies the peace of mind that they are prepared for the rule’s forthcoming implementation.


There are five general categories of industries (also known as “source categories”) that are required to report GHGs for calendar year 2010.  One of the categories includes 17 industries that EPA identified as large GHG emitters, which will report without regard to meeting threshold emission levels.  Other categories of industries, such as stationary combustion sources, are only required to report if the facilities annually emit 25,000 metric tons of carbon dioxide equivalent (CO2e) or more in combined emissions from their sources.  Therefore, it is advantageous for facilities that may be subject to the GHG Mandatory Reporting Rule to identify any applicable source categories and then, if required, determine if they have emitted more than 25,000 metric tons of CO2e.


The product of our high-level review includes identification of applicable source categories, documentation of the rule’s background based on which source categories apply, calculation of emissions using methods provided in the GHG Mandatory Reporting Rule (if applicable), a final conclusion regarding applicability of the rule, and a detailed description of the process we used to reach our conclusion.  You will be given the documentation from the high-level review to maintain on file, if reporting is not required.  If reporting is required, you can use can use the information as the basis for a GHG compliance plan at your facility.

If you would like more information about how we can conduct a high-level review of potential GHG emissions and the applicability of the GHG Mandatory Reporting Rule to your company, please contact Jessica Tierney at 412-779-1094 and or Amy Bauer at 251-533-5949 and



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