A bill, entitled the Greenhouse Gas Registry Act, introduced by Reps. Baldwin (D-WI), Inslee (D-WA), and Holt (D-NJ) would set up new requirements for the Environmental Protection Agency to develop a national greenhouse gas registry. The bill essentially mirrors the greenhouse gas registry requirements proposed in the Lieberman-Warner Climate Security Act of 2008, including the requirement that the registry take into account the best practices of local, state, private, and international registry programs. As a result of this best management requirement, the Greenhouse Gas Registry Act, if enacted, could conflict with EPA's ongoing efforts to establish a greenhouse gas registry.
Aside from this newly introduced bill, EPA is obligated under current law to create a final registry rule by July 1, 2009, and plans to release a proposed version of that rule in the near future. Early reports indicate that EPA's proposed rule may allow regulated entities to "self-report" their greenhouse gas emissions instead of requiring regulated entities to obtain a third-party verification of their greenhouse gas emissions. This move would be in stark contrast with the prevailing standards of international registries and voluntary domestic registries like the California Action Registry, which all require third party verification. Arguably, then, third-party verification is a greenhouse gas registry best practice, and the Greenhouse Gas Registry Act may, therefore, require third-party verification. Consequently, if the Greenhouse Gas Registry Act becomes law and if EPA's forthcoming proposed rules allow for self verification, then EPA's current efforts to create a greenhouse gas registry may be in vain.