Monitoring period begins January 1, 2010

The rule requires reporting of anthropogenic GHG emissions covered under the United Nations Framework Convention on Climate Change (UNFCCC); carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFC), perfluorochemicals (PFC), and sulfur hexafluoride (SF6), as well as other fluorinated gases. These gases are often expressed in terms of carbon dioxide equivalent (CO2e). If you are required to estimate your emissions to determine if your facility is subject to the rule, the applicability determination is based on actual emissions. EPA is not including any facility that has an aggregate maximum rated heat input capacity of stationary fuel combustion units of less than 30 mmBtu/hr and no other emission sources within their boundary.

For sources subject to GHG reporting, the EPA requires that a monitoring plan be developed no later than April 1, 2010 and the plan be updated as the facility gains experience with monitoring equipment and develops more effective procedures for data management. The purpose of the plan is to document the process and procedures for collecting and reviewing the data needed to estimate annual GHG emissions. The plan does not have to be complex and can rely on existing corporate documents like SOPs and monitoring plans developed for compliance with other air programs.

For a list of answers to commonly asked questions about the GHG reporting rule, go to

http://www.epa.gov/climatechange/emissions/ghg_faq.html

If you are uncertain whether or not your facility is subject to the GHG reporting rule, go to

http://www.epa.gov/climatechange/emissions/GHG-calculator/index.html

On May 13, 2010, the EPA issued the GHG Tailoring Rule that sets thresholds for GHG emissions to define when permits under the New Source Review Prevention of Significant Deterioration (PSD) and title V Operating Permit programs are required for new and existing industrial facilities. The Tailoring Rule includes 3 steps:

Tailoring Rule – Step 1 (January 2, 2011 to June 30, 2011)

No new permitting actions due solely to GHG emissions during this time period; only sources undertaking permitting actions anyway for other pollutants will need to address GHG:

-PSD permitting applicability:

·”Anyway” sources will be subject to the PSD requirements only if they increase GHG emissions by 75,000 tpy CO2e or more

-Title V permitting applicability:

·Only those sources currently with title V permits will address GHGs, and only when applying for, renewing or revising their permits

·No sources will be subject to CAA permitting requirements based solely on GHG emissions

Tailoring Rule – Step 2 (July 1, 2011 to June 30, 2013)

Sources subject to GHG permitting requirements under step 1 will continue to be subject to GHG permitting requirements. In addition, sources that emit or have the potential to emit GHGs at or above 100,000 tpy CO2e will also be subject to GHG permitting requirements as follows:

-PSD permitting applicability:

·A newly constructed source (which is not major for another pollutant) will not be subject to PSD unless it emits 100,000 tpy or more on a CO2e basis

·A modification project at a major stationary source will not be subject to PSD unless it results in a net GHG emissions increase of 75,000 tpy or more on a CO2e basis

-Title V permitting applicability

·A GHG emission source (which is not already subject to title V) will not be subject to title V unless it emits 100,000 tpy or more on a CO2e basis

·These newly subject sources must apply for a title V permit on or before July 1, 2012 unless the permitting authority sets an earlier deadline

Tailoring Rule – Step 3

The rule establishes an enforceable commitment to complete another rulemaking no later than July 1, 2012.

For more information regarding the Tailoring Rule, go to

http://www.epa.gov/apti/video/pdfs/tailoring.pdf

If you need any assistance with your GHG requirements, we would be glad to assist you.