ENVIRONMENTAL COMPLIANCE MANUAL
Mandatory Reporting of Greenhouse Gases
The Mandatory Reporting of Greenhouse Gases Rule requires reporting of greenhouse gas (GHG)
emissions from large sources and suppliers in the United States, and is intended to collect accurate
and timely emissions data to inform future policy decisions. Under the rule, suppliers of fossil fuels
or industrial greenhouse gases, manufacturers of vehicles and engines, and facilities that emit
25,000 metric tons or more per year of GHG emissions are required to submit annual reports to EPA.
The gases covered by the proposed rule are carbon dioxide (CO2), methane (CH4), nitrous oxide
(N2O), hydrofluorocarbons (HFC), perfluorocarbons (PFC), sulfur hexafluoride (SF6), and other
fluorinated gases including nitrogen trifluoride (NF3), and hydrofluorinated ethers (HFE).
Reporting is at the facility level, except that certain suppliers of fossil fuels and industrial greenhouse
gases an vehicle and engine manufacturers report at the corporate level. Facilities and suppliers
began collecting data on January 1, 2010. The first emissions report is due on March 31, 2011, for
emissions during 2010. Manufacturers of vehicles and engines outside of the light-duty sector will
begin reporting CO2 for model year 2011 and other GHGs in subsequent model years as part of
existing EPA certification programs.
Reports are submitted annually unless they are facilities with electric generating units that also
report to the Acid Rain Program. Those reporters will continue with current practices, as well as
submit annual GHG emission reports under this rule. The general records retention period is 3
years.
EPA will verify the data submitted and will not require third party verification. Prior to EPA verification,
reporters will be required to self-certify the data they submit to EPA. This is consistent with other
Clean Air Act programs.
The only emission source in the agriculture sector covered by the rule is manure management
systems at livestock operations with GHG emissions that meet or exceed the threshold of 25,000
metric tons. EPA modeling estimates that just over 100 manure management systems at large
livestock operations meet this threshold.
Who must report
Source categories are grouped into four separate reporting categories
All-in source categories. These source categories are automatically required to report.
Threshold-based source categories. These source categories emit 25,000 metric tons of CO2e/
year.
Stationary combustion sources. These are sources with only stationary combustion emissions.
Suppliers. These sources produce, import, or export fossil fuels and industrial GHGs.
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ENVIRONMENTAL COMPLIANCE MANUAL
Table 1. All-in Source Categories
Electricity Generation if report CO2 year-round through Part 75
Adipic Acid Production
Aluminum Production
Ammonia Manufacturing
Cement Production
HCFC-22 Production
HFC-23 Destruction Processes that are not collocated with a HCFC-22 production facility and that destroy more than
2.14 metric tons of HFC-23 per year
Lime Manufacturing
Nitric Acid Production
Petrochemical Production
Petroleum Refineries
Phosphoric Acid Production
Silicon Carbide Production
Soda Ash Production
Titanium Dioxide Production
Municipal Solid Waste Landfills that generate CH4 equivalent to 25,000 metric tons CO2e or more per year
Manure Management Systems with combined CH4 and N2O emissions in amounts equivalent to 25,000 metric tons
CO2e or more per year.
Table 2. Threshold Source Categories: Facilities That Emit at Least 25,000 Metric Tons of CO2e Per
Year From All Sources, Combustion Units, and Miscellaneous Use of Carbonates
Ferroalloy Production
Glass Production
Hydrogen Production
Iron and Steel Production
Lead Production
Pulp and Paper Manufacturing
Zinc Production
Table 3. Stationary Combustion Units: These Sources Must Report if Their Aggregate Maximum
Rated Heat Input Capacity Is at Least 30 MmBtu Per Hour AND They Emit at Least 25,000 Metric
Tons of CO2e Per Year.
Boilers
Stationary Internal Combustion Engines
Process Heaters
Combustion Turbines
Incinerators
Other Stationary Fuel Combustion Equipment
Facilities and suppliers can cease annual reporting by reducing their GHG emissions:
•
After 5 consecutive years of emissions below 25,000 metric tons CO2e/year.
•
After 3 consecutive years of emissions below 15,000 metric tons CO2e/year.
•
If the GHG-emitting processes or operations are shut down.
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The rule affects 40 CFR Parts 86, 87, 89, 90, 94, 98, 1033, 1039, 1042, 1045, 1048, 1051, 1054,
and 1065. More information on the Mandatory Reporting of Greenhouse Gases can be found at:
http://www.epa.gov/climatechange/emissions/ghgrulemaking.html.
Additional source categories
On June 28, 2010, the EPA issued a final rule that requires annual GHG emissions reporting from
four source categories: magnesium production, underground coal mines, industrial waste landfills
and industrial wastewater treatment. This reporting rule amends the Greenhouse Gas Reporting
Program under 40 CFR part 98 to require reporting from additional large emission sources. Facilities
are required to report their emissions to EPA if they emit 25,000 metric tons CO2e or more per year
in combined emissions from source categories covered by 40 CFR part 98.
This action also announced EPA’s final decision not to include ethanol production and food processing or suppliers of coal under the rule at this time.
EPA did not include ethanol production and food processing because the proposals for these
subparts did not include any unique requirements for monitoring or reporting of process emissions.
These types of facilities are still required to report emissions under other subparts of the rule if they
meet the reporting threshold of 25,000 metric tons of CO2 equivalent per year for all covered
emissions sources such as subpart C (stationary combustion), subpart HH (landfills), and subpart II
(wastewater treatment).
For suppliers of coal, EPA did not include reporting requirements because the agency’s near-term
needs for information on GHG emissions from coal consumption can be met through existing
reporting requirements under Part 98, as well as other readily available and existing data sources.
EPA estimates that approximately 680 facilities, responsible for 1 percent of U.S. GHG emissions,
will report under this final rule. The estimated total cost of reporting by the private sector under this
rule would be $7.0 million for the first year of reporting and $5.5 million in subsequent years.
Overview of Reporting Requirements
All underground coal mines that are subject to quarterly (or more frequent) sampling of ventilation
systems by the Mine Safety and Health Administration (MSHA) must report emissions to EPA.
Underground coal mines, magnesium production facilities, industrial waste landfills and industrial
wastewater treatment facilities that meet the reporting threshold must begin monitoring GHG emissions on January 1, 2011 and must submit the first annual report to EPA by March 31, 2012.
EPA has added a provision that will allow facilities in magnesium production, underground coal
mines, industrial waste landfills and industrial wastewater treatment to submit a request to use Best
Available Monitoring Methods as specified in 40 CFR 98.3(d)(1) instead of using the monitoring
methods specified in each subpart for calendar year 2011 monitoring. The use of Best Available
Monitoring Methods will not be approved beyond December 31, 2011.
Data collection for the source categories included in this rule will begin on January 1, 2011, with the
first reports due to EPA on March 31, 2012.
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