Greenhouse Gas Reporting and Monitoring

In October of 2009, the Environmental Protection Agency (EPA) published a final rule for the mandatory reporting of greenhouse gas (GHG) emissions.  The rule, 40 CFR Part 98, is being referred to as the Greenhouse Gas Reporting Program (GHGRP).  So what does this mean and who exactly does this affect? Let’s start with the purpose of the rule and its intended outcome.  According to the EPA, the collection of nationwide data “will provide a better understanding the sources of GHGs and will guide development of the policies and programs to reduce emissions”.  The data will also be available to the public which will allow facilities to compare themselves to similar facilities and to track their own emissions.

Maybe more important is who this rule will affect.  The rule itself will apply to direct greenhouse gas emitters, fossil fuel suppliers, industrial gas suppliers, and facilities that inject carbon dioxide (CO2) underground for sequestration or other reasons.  This won’t apply, however, to all facilities within these categories.  The threshold for reporting is 25,000 metric tons or more of CO2 equivalent per year.  The EPA estimates that approximately 13,000 facilities in the U.S. will be affected by the rule.

The rule is divided into subparts that cover the 41 industrial categories required to report under the rule.  These categories cover various industries including electricity generation, cement production, glass production, pulp and paper manufacturing, municipal solid waste landfills, and industrial wastewater treatment.  If a facility is above the threshold and required to report, they will do so by utilizing the electronic greenhouse gas reporting tool, e-GGRT, which is accessed through the EPA website.  Reports will be due on March 31st for the previous calendar year.  More information on the reporting tool is presented in a previous blog post by EES, found here.

The EPA also provides an applicability tool on its website.  This can be used to determine if your facility is required to report.  The tool is based on your source category and cannot be used for suppliers of fossil fuels, suppliers of industrial GHGs or engine manufacturers.

In addition to reporting, the rule requires other items for those facilities that must report.  One of these is the use of Best Available Monitoring Methods (BAMM).  These methods and requirements differ for each subpart, or industrial category.  They refer to monitoring emission parameters and calculation methods for transforming the parameter data into GHG estimates.  Using these methods can replace the requirements to install and operate monitoring equipment.  If BAMM is used, a facility’s annual report must then include the following:

  • Brief descriptions of each BAMM used.
  • The parameter measured using that method.
  • The time period during which the method was used.

Additionally, the rule requires that every facility subject to the rule is required to create and adhere to a GHG monitoring plan.  The elements that must be included in the plan can be found in 40 CFR 98.3(g)(5)(i) of the rule and include the following major elements:

  • Identification of positions of responsibility (i.e., job titles) for collection of the emissions data.
  • Explanation of the processes and methods used to collect the necessary data for the GHG calculations.
  • Description of the procedures and methods that are used for quality assurance, maintenance, and repair of all continuous monitoring systems, flow meters, and other instrumentation used to provide data for the GHGs reported under this part.

These GHG monitoring plans will not be submitted to the EPA, but must be kept on site.

Determining if your facility needs to report as well as creating the monitoring plan to comply with the rule can be a difficult process.  Emission calculations are required to determine your facility’s total GHG emissions for the year.  A working knowledge of the rule and its requirements is necessary to ensure compliance with the rule.  Using an outside consultant with experience in GHG reporting may be desirable.  Contact me at 215-881-9401 for further details on EES consulting assistance for GHG inventories and monitoring plans.

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