EPA Proposed Mandatory Greenhouse Gas Reporting Rule

The purpose of the rule is to collect “comprehensive and accurate” data on GHG emissions that can be used to inform future policy decisions The purpose of the rule is to collect “comprehensive and accurate” data on GHG emissions that can be used to inform future policy decisions No direction on the development of emission reduction or control No direction on the development of emission reduction or control It is not meant to be a registry tracking individual projects or reductions It is not meant to be a registry tracking individual projects or reductions After it is published in the Federal Register, there will be a 60 day comment period (probably w/ additional 30 days) After it is published in the Federal Register, there will be a 60 day comment period (probably w/ additional 30 days) EPA wants to publish the final rule before the end of the year EPA wants to publish the final rule before the end of the year The proposed rule and preamble are extensive (1400+ pages) The proposed rule and preamble are extensive (1400+ pages) In addition In addition Technical Support Documents Technical Support Documents Regulatory Impact Statement Regulatory Impact Statement Overview of the Reporting Rule

Regulated Gases Mandatory reporting of GHGs would require reporting of annual emissions of: Mandatory reporting of GHGs would require reporting of annual emissions of: Carbon Dioxide (CO 2 ) Carbon Dioxide (CO 2 ) Methane (CH 4 ) Methane (CH 4 ) Nitrous Oxide (N 2 O) Nitrous Oxide (N 2 O) Sulfur Hexafluoride (SF 6 ) Sulfur Hexafluoride (SF 6 ) Hydrofluorocarbons (HFCs) Hydrofluorocarbons (HFCs) Perfluorochemicals (PFCs) Perfluorochemicals (PFCs) Other Fluorinated Gases (e.g. NF 3, HFEs) Other Fluorinated Gases (e.g. NF 3, HFEs)

Proposed Sectors and Sources

Schedule for Reporting Facilities and suppliers would begin collecting data on January 1, 2010 Facilities and suppliers would begin collecting data on January 1, 2010 First emissions report would be due on March 31, 2011 First emissions report would be due on March 31, 2011 New vehicles and engine manufacturers would start reporting w/ the 2011 model year New vehicles and engine manufacturers would start reporting w/ the 2011 model year Reports would be submitted annually Reports would be submitted annually

What Information Would be Reported? Total GHG emissions in MT of CO 2 E from all source and supply categories: Total GHG emissions in MT of CO 2 E from all source and supply categories: Gas Gas Breakdown emissions w/in each source category (e.g. unit or process level) Breakdown emissions w/in each source category (e.g. unit or process level) Activity data Activity data

How Would Reports be Submitted? Facilities would report directly to the EPA Facilities would report directly to the EPA Electronic reporting Electronic reporting Self-certification by Designated Representative Self-certification by Designated Representative

Landfills

Who reports? Required Required Open and closed MSW landfills Open and closed MSW landfills Industrial landfills Industrial landfills Not-required Not-required Hazardous waste landfills Hazardous waste landfills Construction and demolition landfills Construction and demolition landfills

Threshold Evaluated Thresholds Evaluated Thresholds Generation Threshold Generation Threshold 1,000, 10,000, 25,000, 100,000 MT CO 2 E of CH 4 generation at a landfill minus soil oxidation 1,000, 10,000, 25,000, 100,000 MT CO 2 E of CH 4 generation at a landfill minus soil oxidation Emissions Threshold Emissions Threshold 1,000, 10,000, 25,000, 100,000 MT CO 2 E of CH 4 emissions from a landfill, minus oxidation after any destruction of landfill gas 1,000, 10,000, 25,000, 100,000 MT CO 2 E of CH 4 emissions from a landfill, minus oxidation after any destruction of landfill gas Proposed threshold for reporting emissions is a generation threshold of 25,000 MT CO 2 E Proposed threshold for reporting emissions is a generation threshold of 25,000 MT CO 2 E

Evaluated Monitoring Methods First Order Decay Model First Order Decay Model Engineering Method Engineering Method Direct Measurement Direct Measurement

EPA Proposed Methods First Order Decay Model First Order Decay Model Bulk waste option Bulk waste option Waste material specific option Waste material specific option Required for industrial landfills Required for industrial landfills Recommended for MSW landfills if data is available Recommended for MSW landfills if data is available Engineering Method Engineering Method Required for landfills that have gas collection systems Required for landfills that have gas collection systems

Comments Exclusion of land application units Exclusion of land application units Monthly sampling of landfill gas CH 4 flow and concentration as an alternative to continuous composition analyzer Monthly sampling of landfill gas CH 4 flow and concentration as an alternative to continuous composition analyzer

Regulatory Impact Statement Costs were developed to model emissions using the First Order Decay method Costs were developed to model emissions using the First Order Decay method Labor Costs Labor Costs $900/reproting unit/facility for the 1 st year $900/reproting unit/facility for the 1 st year $400/reporting unit/facility for subsequent years $400/reporting unit/facility for subsequent years Capital and O&M Costs Capital and O&M Costs $650/reporting unit/facility for the 1 st year $650/reporting unit/facility for the 1 st year $1100/reportig unit/facility for subsequent years $1100/reportig unit/facility for subsequent years Electricity Use, Recordkeeping, and Reporting Costs Electricity Use, Recordkeeping, and Reporting Costs $1700/entity for electricity use and recordkeeping $1700/entity for electricity use and recordkeeping