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Mandatory Reporting of Greenhouse Gases
On September 22, 2009, the EPA Administrator signed the Mandatory Greenhouse Gas Reporting Rule. The
rule requires facilities that emit 25,000 metric tons or more of CO2 equivalent per year, to report GHG
emissions data to the EPA annually beginning with calendar year 2010. The rule will allow the EPA to collect
accurate emissions data from large emissions sources. For more information, visit the EPA’s website:
http://epa.gov/climatechage/emissions/ghgrulemaking.html
The Status of Greenhouse Gas Regulations
EPA and Congress are building the framework to regulate greenhouse gas emissions. The following tasks are
currently under pursuit by the EPA:
Task 1: Carbon Dioxide Endangerment and Cause or Contribute Finding - On April 17, 2009
the EPA Administrator signed the Proposed Endangerment and Cause or Contributed Finding for Greenhouse Gases.
The proposed endangerment finding determined that greenhouse gas emissions threaten the public health and
welfare of current and future generations. The cause or contribute portion of the proposal finds that
greenhouse gas emissions from motor vehicle engines contribute to the atmospheric concentration of the
greenhouse gases identified, therefore contributing to the threat of climate change. For more information, visit the EPA’s website:
http://epa.gov/climatechange/endangerment.html
Task 2: Proposed Light-Duty Vehicle Greenhouse Gas Emissions Standards - On September 15, 2009, EPA
and the Department of Transportation’s National Highway Safety Administration proposed a program to establish
CO2 emission limits and fuel economy standards for passenger cars, light-duty trucks and medium duty
passenger vehicles sold in the US, beginning with vehicle model year 2012. The amount of carbon dioxide emitted
from a vehicle is directly related to the amount of fuel combusted. Therefore, improving the fuel economy of a
vehicle results in a reduction in greenhouse gases emitted over the same distance travelled.
The endangerment findings must be finalized before the EPA can finalize the proposed light-duty vehicle greenhouse
gas emissions standards. Once these standards are enacted, the EPA will officially be regulating greenhouse gases
which will have significant ramifications for all large emitters of carbon dioxide. For more information, visit the EPA’s website:
http://epa.gov/otaq/climate/regulations.htm
Task 3: Controlling Greenhouse Gas Emissions from Stationary Sources - Two options are currently being pursued:
- Proposed PSD and Title V Greenhouse Gas Tailoring Rule - On September 30, 2009, the EPA announced a proposed rule that
would add New Source Review and Title V requirements to facilities that emit 25,000 tons of CO2 equivalent per year.
The rule proposes to increase the major source threshold and significance level for GHG emissions for new stationary sources,
from the current 250 tpy and 100tpy limits for currently regulated pollutants. For more information, visit the EPA’s website:
http://www.epa.gov/NSR/fs20090930action.html
- Greenhouse Gas Cap and Trade - Congress is drafting a Cap and Trade legislation that will force greenhouse gas emission reductions.
The exact details of any Cap and Trade bill are unknown at this time. However, a Cap and Trade bill will establish a greenhouse gas
emission cap (maximum number of allowances) that will be reduced over time. Each year, a set percentage of allowances will be
allocated to sources of GHG emissions. The remainder of the allowances will be auctioned off. Therefore, sources must reduce
their emissions to their allocated limit or buy additional credits. If a Cap and Trade bill is passed, the outlook for regulating
greenhouse gases by the Clean Air Act under NSR or Title V is uncertain. These regulations will be made in the Cap and Trade bill,
if it is passed. For more information on active legislation, visit the Senate’s website:
http://senate.gov/pagelayout/legislative/b_three_sections_with_teasers/active_leg_page.htm
In summary, the regulation of greenhouse gases in the US is awaiting finalization of the Proposed Findings in Task 1. Once
that occurs, the new efficiency standards (Task 2) will likely be implemented requiring concurrent action in regulating
greenhouse gas emissions as discussed in Task 3.
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Are you prepared for possible greenhouse gas regulations?
Several U.S. companies are already working to address possible greenhouse gas regulations. These companies
have determined their greenhouse gas emissions and have started developing reduction strategies. These companies
are now able to effectively answer questions from stakeholders regarding what they are doing to address climate change
and greenhouse gasses. In addition, these proactive companies are acting as environmental stewards and boosting their
public image.
JCA can help transform your company into a proactive company. JCA will to put you on the right track regarding greenhouse gases for
a nominal fee.
JCA’s approach is to start by educating you on the current regulatory environment relating to greenhouse gasses including
current greenhouse gas registries. This ensures everyone is on the same page at the beginning of the project. Next, we prepare a
baseline greenhouse gas emission inventory. This inventory will let you know your current greenhouse gas emissions and give you a
baseline to measure future greenhouse gas reductions against. Then JCA will develop a system to track and report greenhouse gas
emissions data. Finally, JCA works with you to develop a greenhouse gas emissions management strategy including reduction strategies.
JCA’s program helps your company answer questions regarding greenhouse gas emissions and provides accurate information for
stakeholders. JCA’s greenhouse gas program also allows your company to properly prepare for possible regulations. Our program
shows the public that your company is acting in an environmentally responsible manner in regards to greenhouse gasses.
Let JCA help your company address the issue of climate change. Please contact Jim Clary at (972) 386-5995 x102 or email us at info@jcaenv.com for more information. |