Six months overdue, the U.S. Environmental Protection Agency (U.S. EPA) finally rolled out its proposed Greenhouse Gas (GHG) mandatory reporting rule today. The proposed rule (with preamble) is a hefty 1,350 pages and was mandated by Congress more than a year ago.

The proposed rule requires:

  • Mandatory annual reporting of GHG emissions from facilities in certain source categories and from other facilities with at least 25,000 metric tons of carbon dioxide (CO2) equivalent[1] emissions per year.
  • Facilities in the following sectors are the primary, but not the only targets of the proposal:
    • Electricity Generators[2],[3];
    • Electric Power Systems[4];
    • Vehicle & engine manufacturers[5];
    • Metal, minerals, cement, chemical, mining, petroleum refining, electronics, petrochemical producers;
    • Suppliers of fossil fuels (natural gas and coal) and industrial gases;
    • Manure Management Systems and Landfills[3].
  • Data collection to begin in 2010, with the first report due to U.S. EPA in 2011.
  • U.S. EPA opted not to use "third party verification" and will verify the data itself and assess penalties for failure to report and/or reporting discrepancies.
  • U.S. EPA claims its reporting methods are built on and follow existing GHG reporting schemes already established by public/private entities and several states.
  • U.S. EPA will hold public hearings April 6-7, 2009, in Arlington, VA, and April 16, 2009, in Sacramento, CA.
  • A 60-day public comment period on the proposed rule begins when the rule is published in the Federal Register.
  • A pre-publication copy of the rule, as well as supporting documents can be found at

Future environmental alerts will highlight specific issues/segments of the proposed rule.