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:

1. 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


2. 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.

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.