U.S. EPA Proposes Mandatory Greenhouse Gas Emission Inventory Reporting Rules
Cement Sector
Have you heard the news? On March 10, 2009, U.S. EPA released its proposed Mandatory Greenhouse Gas (GHG) Emission Inventory Reporting Rules at 40 CFR Part 98, breaking ground for a long-anticipated national program. Public hearings on the proposed rule will be held during April 2009. Public comments will be accepted for 60 days following publication of the rule in the Federal Register.
ALL4's Climate Change Team has closely monitored and commented on the regional, state, and local policy and programs that have developed in recent years due to the absence of a comprehensive national GHG program. While it is still unclear whether the U.S. is moving toward a cap-and-trade or carbon tax program (see
ALL4's March 2009 4 The Record) the recently proposed Federal rulemaking can still be appreciated as a major development in domestic climate change policy as it will provide U.S. EPA with reliable GHG emissions data. Access to this data set will enable U.S. EPA to support the efforts of existing programs as well as the development and implementation of stronger policy in the future.
Unlike voluntary programs such as Climate Leaders or The Climate Registry (TCR), the proposed rulemaking would be applicable (and mandatory) at the facility-level, as opposed to the company-level. U.S. EPA estimates that there are 13,000 upstream producers or downstream sources that emit 25,000 metric tons of carbon dioxide equivalent (MT CO2e) that will be subject to the proposed reporting rules (List of named source emitters, threshold emitters, and named fuel source suppliers). Thus your facility could be required to begin collecting GHG emissions data on January 1, 2010, and submit annual reports to U.S. EPA beginning in 2011. ALL4's Climate Change Team has reviewed the detailed list of affected facilities included at 40 CFR Part 98, Subpart A and has summarized the applicability, recordkeeping, monitoring, calculation, reporting, and self-verification requirements your source of facility.
In general, any facility subject to the requirements of 40 CFR Part 98 would be required to collect emissions data, calculate GHG emissions, and follow the procedures for quality assurance, missing data, recordkeeping, and reporting that are specified in its subpart.
The General Provisions at 40 CFR Part 98.3(c) would require each facility to report emissions of carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), and each fluorinated GHG on an annual basis in accordance with 40 CFR Part 98.2(c)(1) through (8). Affected facilities would be permitted to submit an abbreviated emissions report for 2010 in accordance with 40 CFR Part 98.3(d)(1) through (5) with the understanding that a full emissions report would be required each year thereafter.
Recordkeeping requirements for each affected facility are specifically discussed within each subpart; however, in general, records would need to be retained for at least five (5) years in accordance with 40 CFR Part 98.3(g). U.S. EPA has also indicated that a quality assurance project plan (QAPP) must be prepared for each facility subject to reporting.
The owner or operator a facility subject to Part 98 would be required to self-certify the facility's emissions data before submitting to U.S. EPA. Verification of each facility's emissions is performed by U.S. EPA upon receipt.
Read on as
ALL4's Climate Change Team addresses the Cement Sector (including stationary fuel combustion).
The summary presented in the article reflects the initial review of your GHG reporting requirements as proposed by U.S. EPA. You may have already initiated a GHG inventory program that is equivalent to or more ambitious that what has been proposed. ALL4 is prepared to assist you assess with reconciling an existing inventory or helping you start an initial inventory. Please contact ALL4's
Dan Holland or
Cara Fox at 610-933-5246 x 15 or 23, respectively or
dholland@all4inc.com or
cfox@all4inc.com to find out more on the industry-specific GHG inventory requirements you are facing, to discuss options around submitting comments on the reporting requirements to U.S. EPA, and to learn about
ALL4's Greenhouse Gas Inventory Starter Kit. 
