The Environmental Protection Agency (EPA) has issued four new proposed rules to amend the Mandatory Greenhouse Gas (GHG) Reporting Rule. Three of the proposed rules would expand the applicability of the existing rule to cover petroleum and natural gas systems, industries that emit fluorinated GHGs, and facilities that inject and store carbon dioxide underground for the purposes of geologic sequestration or enhanced oil and gas recovery. These newly covered sources would be required to begin collecting emissions data on January 1 2011 and to submit the first annual reports on March 31 2012.

In addition, the EPA proposes to add three reporting requirements applicable to all facilities, requiring provision of the following information:

  • the name, address and ownership status of the reporter's US parent company;
  • the reporter's primary and all other applicable North American Industry Classification System codes; and
  • an indication of whether any of the reported emissions are from a cogeneration unit.

The EPA plans to finalize all four of these proposed rules this year. Comments are due by June 11 2010. More information can be found at

For further information on this topic please contact Jennifer Coghlan at Sive Paget & Riesel PC by telephone (+1 212 421 2150), fax (+1 212 421 2035) or email (

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