September 2009 – Mandatory Reporting of Greenhouse Gases Now a Reality

Beginning on January 1, 2010, large sources and suppliers of greenhouse gases (GHGs) will be required to begin collecting data and annually reporting GHG emissions as required by the Final Mandatory Reporting of Greenhouse Gases Rule, which was signed by U.S. Environmental Protection Agency (EPA) Administrator Lisa Jackson on September 22, 2009. The threshold for reporting is 25,000 metric tons or more of carbon dioxide equivalent (CO2) per year. Reporting will be required at the facility level for most facilities, except for certain fossil fuel and greenhouse gas suppliers and vehicle and engine manufacturers who will be required to report at the corporate level. EPA estimates that the rule will cover approximately 85 percent of the GHGs emitted in the U.S. from approximately 10,000 facilities. The first mandatory reports will be due March 31, 2011, for emissions during 2010.EPA issued the proposed rule on March 10, 2009, and received close to 17,000 comments. In response, EPA made several key changes in the final rule, including:

  • Reduced the number of covered source and supply categories
  • Provided a mechanism for exiting the program by reducing GHG emissions
  • Reduced record retention requirements from 5 years to 3 years
  • Added a provision to allow use of best available monitoring methods in lieu of the required monitoring methods for January – March 2010

EPA describes these changes and other key changes in a Fact Sheet available at:

According to EPA, the rule “…is intended to collect accurate and timely emissions data to inform future policy decisions.” EPA estimates the average cost of reporting for the private sector under this rule will be approximately $115 million in the first year of reporting and $72 million in subsequent years.

To assist the regulated community, EPA has developed information and training resources, including an online applicability tool, a series of webinars, and information sheets on reporting requirements for each of the covered sectors, which are available at:

How can EHS Support assist you in complying with the new rule?
We can assist you with determining applicability of the rule to your operations, estimating GHG emissions, and preparing the mandatory annual report.

For more information or for assistance with meeting the requirements of the new rule, please contact Jessica Tierney at 412-779-1094 and or Amy Bauer at 251-533-5949 and




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