Next Steps Regarding Mandatory GHG Reporting

The US EPA published the Mandatory Reporting of Greenhouse Gases Rule in the Federal Register on October 30.  What does this mean for your facility and how can you best prepare for compliance?

Now that the rule has been printed in the Federal Register, key compliance dates have been established.  The rule becomes effective 60 days after promulgation - on December 29, 2009 - and facilities should be aware of the following key dates:

  • January 1, 2010 - Start collecting data to calculate your 2010 GHG emissions inventory
  • January 28, 2010  - Deadline for submitting application to extend use of best available monitoring methods (must be submitted no later than 30 days after effective date of the rule)
  • March 31, 2010 - Monitors must be installed and calibrated.  Begin using required monitoring methods (if an extension is not obtained).
  • April 1, 2010 - Have initial calibration completed for flow meters, scales, etc. used to gather GHG data (fuel billing meters excluded under certain circumstances[1]).
  • April 1, 2010 - No deadline for submittal of Monitoring Plan, however it must be in place if audited by EPA - generally expected to be in place by April 1, 2010

Facilities should start preparing for these deadlines by: 

  • Analyzing your existing GHG inventory and determining whether the facility is subject (documenting non-applicability as appropriate)
  • Conducting a gap analysis of your calculation methodologies, monitoring, recordkeeping and reporting requirements compared to the requirements of the rule
  • Developing a plan for closing the gaps between existing methodologies/practices and the rule requirements
  • Conducting the necessary steps to determine if your facility should file for an extension request (i.e., may require researching vendors for monitoring equipment upgrades)
  • Developing your required Monitoring Plan
  • Calibrating your equipment to meet the calibration requirements of the rule
  • Start collecting the appropriate data for the 2010 emissions inventory

With these steps completed, your facility will be well on the way toward sound compliance with the Mandatory Reporting Rule and better positioned to address the GHG mitigation programs that may lie ahead. 
 
Trinity has developed tools and templates to assist organizations in determining applicability and complying with this significant new rule.  For assistance at your facility, contact your nearby Trinity office at (800) 229-6655 or Katherine Blue, Climate Change Practice Leader at (404) 256-1919 or kblue@trinityconsultants.com.

[1]Fuel billing meters are excluded from calibration requirements, per §98.3(h)(i)(4), "provided that the fuel supplier and any unit combusting the fuel do not have any common owners and are not owned by subsidiaries or affiliates of the same company."