1. Voluntary Programs and Mandated Actions Susan Wickwire Energy Supply & Industry Branch Office of Atmospheric Programs March 23, 2010

2. Chronology of Voluntary and Mandatory Programs Green Lights/ENERGY STAR – launched early 90s Methane capture programs (e.g., landfills, coal mines) – mid 90s Climate/clean energy programs (e.g., Climate Leaders, CHP Partnership, Green Power Partnership) - 2001-2002 Mandatory GHG Reporting rule finalized – 2009 Release of proposed GHG stationary source permitting rule - 2009

3. Climate Leaders Climate Leaders works with organizations to develop a long-term comprehensive GHG management strategy Road-tested with ~ 200 partners from every major sector across the country, representing 8% U.S. emissions and 12% U.S. GDP –Increase in participation as mandatory approaches became more likely 3 critical components to credible strategy: –1) Complete Corporate-Wide GHG Inventory –2) Develop Inventory Management Plan (IMP) –3) Set Aggressive Corporate-Wide GHG Reduction Goal Helped establish standards for reporting and increased corporate awareness and action during previous Administration Valuable role to play before mandated actions are implemented and potentially after

4. Mandatory Reporting Rule (MRR) Emissions-based threshold of 25,000 metric tons of CO 2 e per year for most sources (other than mobile sources) Opt-out options for facilities that fall below the threshold Approx. 85% of total U.S. greenhouse gas emissions covered by rule (about 10,000 reporters) Data collection began January 1, 2010 with first reports submitted to EPA March 31, 2011 Self-certification with EPA verification Mobile sources - reports from fuel suppliers and makers of vehicles and engines (outside of the light- duty sector)  No requirements for fleet operators

5. Climate Leaders and the MRR Participation in CL prepared high-emitting Partners for future mandatory reporting CL staff participation in internal MRR workgroups to develop rule Overlap between CL and MRR limited to large direct emissions – important role for CL in reducing Scope 2 emissions Coordination between CL and MRR – outreach efforts to relevant groups MRR contributes to transparency of all companies’ GHG inventories

6. Permitting for Stationary Sources – “GHG Tailoring Rule” Proposes to raise the “major source” thresholds and PSD “significance levels” –PSD and Title V: major source size raised to 25,000 tons/year CO2e (sum of 6 gases) –PSD significance level: raised to a number within the range of 10,000-25,000 tons/year CO2e (sum of 6 gases) –Proposal took comment on other levels Facilities above these levels would still be required to obtain permits –Facilities that remain covered are responsible for nearly 70 percent of stationary source GHG emissions –Facilities proposed for exclusion comprise only 7 percent Small farms, restaurants, office buildings, etc. would not need to get permits February letter from Administrator Jackson to U.S. Senators sheds additional light on EPA approach

7. Other Climate Leaders Policy-Related Actions Testing ground for EPA offsets approach Provided technical assistance to carbon labeling provisions in H.R. 2454 Participating in USG effort to inventory GHG emissions and set goals