Soon, all businesses from Animal feedlots to Zinc production and countless operations in-between (cement production, coal mining, electronics manufacturing, food processing, pulp and paper manufacturing, solid waste management, wastewater management, etc.) will be required to calculate and report to the U.S. EPA the amount of greenhouse gases (GHGs) their facilities emit.

On March 10, 2009, U.S. EPA Administrator Lisa Jackson signed the proposed mandatory GHG reporting rules, to establish the first comprehensive national system for reporting emissions of GHGs produced by major sources in the United States. The GHGs covered by the proposed rule include carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, sulphur hexafluoride, nitrogen trifluoride and hydrofluorinated ethers. After the U.S. EPA formally publishes the proposed GHG reporting rules in the Federal Register in the next few weeks, the regulated community will have 60 days to comment on the proposed rules.

U.S. EPA estimates that approximately 13,000 facilities will be subject to the proposed rules and that 85-90% of total GHG emissions will be covered. Currently, other than for fossil fuel suppliers such as coal mines and industrial gas suppliers, the proposed GHG reporting rules do not cover indirect emissions from the purchase and consumption of electricity, heat, and steam. However, U.S. EPA has said they are "carefully considering" whether to add this requirement. For example, a high school may have two one million Btu boilers to heat the building and buy electricity from a public utility to light the building. The boiler produces direct emissions while the lighting produces indirect emissions. As the reporting rules are currently written, the rules would not cover the school because the school is not within a source category identified by the rules and the heating capacity of its boilers is less than 30 million Btu/hour. However, if indirect emissions reporting is added, facilities such as school buildings may become subject to the GHG reporting rules.

The U.S. EPA has stated explicitly that the proposed rule will not change or supplant state or regional GHG reporting rules. Therefore, a facility located in a state with mandatory reporting requirements could be required to submit two different reports for GHGs--one state and one federal.

Under the proposed rules as currently drafted, data collection will begin January 10, 2010, with the first emission reports for 2010 submitted electronically to the U.S. EPA by March 31, 2011. The U.S. EPA is not proposing third-party verification of GHG emission reports. Instead, the Agency will require that each report be signed by a designated representative of the owner/operator, certifying under penalty of law that the report has been prepared in accordance with the rules.