By March 31, certain facilities that emit greenhouse gases must submit a mandatory annual report, required under the CAA. Whether or not your site must report can depend on a number of factors, including your industry and the amount of greenhouse gases your site emits. The thresholds for reporting, and details on how to report, are covered below.
Due to recent changes to the program, some previously unregulated facilities are now subject to the reporting rule. Also, some previously regulated facilities may no longer be required to report on their greenhouse gas emissions.
Identifying Greenhouse Gases
The Environmental Protection Agency defines greenhouse gases as “carbon dioxide, methane, nitrous oxide, sulfur hexafluoride, hydrofluorocarbons, perfluorocarbons and other fluorinated greenhouse gases.” [40 CFR 98.6] These are the gases that are internationally recognized to have a measurable impact on climate change/global warming. The Consolidated Appropriations Act of 2008 authorized EPA “to require mandatory reporting of greenhouse gas emissions above appropriate thresholds in all sectors of the economy of the United States.” [P.L. 110-161, 121 Stat 1844, 2128]
The “appropriate thresholds” are assigned based on the industry you are in and are delineated in 40 CFR 98. Certain facilities must report every year, regardless of the amount of GHG emissions (for instance, electricity generation [40 CFR 98, Subpart D], petrochemical production [Subpart X], and municipal landfills [Subpart HH]). Facilities in other sectors must report only if their annual CO2e (carbon dioxide equivalent) GHG emissions are equal to or greater than 25,000 metric tons (for instance, electronics manufacturing [Subpart I], fluorinated gas production [Subpart L], and industrial wastewater treatment [Subpart II]). Sites with stationary fuel combustion sources and greenhouse gas suppliers must also report annually.
Carbon Dioxide Equivalent Emissions
Each regulated greenhouse gas has a different potential to impact climate change. To accommodate this, the EPA uses “carbon dioxide equivalent” (CO2e) to standardize the measurement of all greenhouse gas emissions relative to the same amount of carbon dioxide emissions. The rule contains a table (40 CFR 98, Table A-1) that assigns a specific “global warming potential” (GWP) to each regulated GHG as it compares to an equivalent amount of carbon dioxide. To calculate the CO2e for a given GHG, EPA requires facilities to use this formula:
CO2 = Σ GHG x GWP
Where GHG = amount of greenhouse gas emitted and GWP = global warming potential for that GHG
New Reporting Thresholds for 2014
Due to changes in GWP’s for a handful of greenhouse gases, some facilities may be required to report for the first time in 2014. EPA’s Table A-1 to Subpart A of 40 CFR 98 is based on the Intergovernmental Panel for Climate Change’s (IPCC) assessment reports. In a final rule promulgated on November 29, 2013, EPA amended Table A-1 to bring it into agreement with the IPCC’s Fourth Assessment Report (or “IPCC AR4″) issued in 2007. For certain greenhouse gases, the GWP has changed, and reports submitted in 2014 will need to reflect these changes. For instance, methane’s GWP increased from 21 to 25, while nitrous oxide’s dropped from 310 to 298.
Electronic Reporting is Now Mandatory
On December 19, 2013, EPA announced that the Electronic Greenhouse Gas Reporting Tool (e-GGRT) is now accepting best available monitoring methods (BAMM) requests from facilities and suppliers who are newly subject to 40 CFR Part 98 as a result of the changes to the global warming potential. Guidance can be found on EPA’s website.
The deadline for reporting is March 31. All reports must be submitted electronically through the e-GGRT. Paper submissions are not accepted. For security and confidentiality, facilities must register with the e-GGRT before filing reports. This process can be lengthy. EPA provides support via phone (877-444-1188) and e-mail GHGMRR@epa.gov.
NewClean Air Act RegulationsNow Available
A new online course is now available to help environmental engineers, EHS managers, and compliance officers keep their facilities in compliance with the US EPA’s Clean Air Act programs. The Clean Air Act Regulations guides professionals through compliance with Title V permit requirements, emissions and pollution controls, annual greenhouse gas (GHG) reporting, Risk Management Planning (RMP) responsibilities, and more.
Build the expertise needed to make informed on-the-job decisions that help your site control pollution and maintain compliance. Interactive, easy to use, and available 24/7, the new online course will help you get up to speed with new and changing EPA clean air rules and protect your facility from costly EPA enforcement.
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