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BHGR Newsletter: EPA Proposes New GHG Reporting Rules

May 2009

The EPA is proposing new regulations to require monitoring and reporting of greenhouse gas (GHG) emissions from all sectors of the economy. The rules would apply to direct greenhouse gas emitters including power plants, refineries, landfills, and manufacturing facilities, as well as fossil fuel suppliers and industrial gas suppliers.

The rules would require annual reporting of the emissions of carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF6), hydrofluorocarbons (HFCs), perfluorochemicals (PFCs), and other fluorinated gases. The proposed rules would apply primarily to large facilities emitting at least 25,000 tons per year of CO2 equivalent GHG emissions and to suppliers of fossil fuels and industrial GHGs, as well as to manufacturers of vehicles and engines.

This reporting requirement is a precursor to substantial new regulations on greenhouse gas emissions. BHGR recommends that clients inventory their greenhouse gas emissions in anticipation of having to report them. The public comment period for the proposed rules ends June 9, 2009. See http://www.epa.gov/fedrgstr/EPA-AIR/2009/April/Day-10/a5711.pdf.

If you have questions about the above reporting rules, contact our experienced team of Environmental & Water Law, and Natural Resource Development Practice Groups.

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