GHG Mandatory

Reporting Rule: Proposal Overview

Presented toPhiladelphia Diesel Difference Working Group

By Jim Smith, EPA Region 3November 9, 2009

November 9, 2009 JAMES D. SMITH 2

Outline

Background / PurposeSummary of RuleWho ReportsGases CoveredSources Covered Related IssuesSources of Information

November 9, 2009

Background

• Directed by Congress in 2008 Appropriations Act• Proposal signed March 10, 2009• Public Comment Period (April 10 – June 10,

2009)• Final rule signed September 22, 2009• Published in Federal Register October 30, 2009• Takes Effect December 29, 2009

JAMES D. SMITH 3

November 9, 2009

Main Purpose

• Provide accurate and timely data to inform future climate change policies and programs– Better understand relative emissions of

specific industries, and of individual facilities within those industries

– Better understand factors that influence GHG emission rates and actions facilities could take to reduce emissions

• Does not require control of GHGJAMES D. SMITH 4

November 9, 2009

Other Aims• Minimize the number of sources and cost of

reporting yet maximize the quantity of emissions: – The 25,000 ton threshold captures 85% of emissions

from roughly 10,000 facilities– 25,000 mtCO2e are equivalent to emissions from the

annual energy use of approximately 2,300 homes.

• Minimize the number of sources required to calculate emissions to determine applicability:– Equivalent capacity thresholds were provided when

possible.

JAMES D. SMITH 5

November 9, 2009

Changes resulting from comments on Proposed Rule

• Reduced the number of source and supplier categories that must report

• Added a mechanism to allow exit from reporting when GHG emissions reduced

• Added flexibility in monitoring methods and sampling frequency

• Added exemptions for combustion sources• Added thresholds to reduce the burden of

determining applicability

JAMES D. SMITH 6

November 9, 2009 JAMES D. SMITH 7

Summary of Rule• Who Reports:

– Facility/supplier reports directly to EPA (states not directly involved)– Facility based reporting for all source categories for which there are methods– Limited exceptions for some (e.g. fuel importers, vehicle and engine

manufacturers)• What gases are covered:

– carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFC), perfluorocarbons (PFC), and sulfur hexafluoride (SF6), as well as other fluorinated gases (e.g. nitrogen trifluoride and hydrofluorinated ethers [HFEs]).

• Applicability:– Facilities and suppliers of fossil fuels or industrial greenhouse gases that have:

• a source in an all-in source category (Table 1) or• a source in a threshold source category (Table 2) and emissions ≥ 25,000

tons CO2e per year or• a combustion unit included in Table 3 with an aggregate maximum rated

heat input capacity ≥ 30 mmBtu/hr and emissions ≥ 25,000. – or manufacturers of vehicles and engines

November 9, 2009 JAMES D. SMITH 8

Summary of Rule:Source Categories Covered

Sector Reporters

Electricity Generation Power plants

Transportation Vehicle and Engine Manufacturers (vehicle fleets not covered)

IndustrialAll large industrial emitters, including those in the following industries:

Metals Iron and Steel, Aluminum, Ferroalloy, Zinc, and Lead

Minerals Cement, Lime, Glass, Silicon Carbide, Pulp and Paper

Chemicals

HCFC-22, Ammonia, Nitric Acid, Adipic Acid, Hydrogen, Petrochemicals, Petroleum Refineries, Soda Ash, Phosphoric Acid, Titanium Dioxide

Agriculture Manure Management

OtherLarge Stationary Combustion Units, Municipal solid waste landfills

Upstream Suppliers*Carbon Dioxide, Coal-based Liquids, Industrial Gases, Natural Gas and Natural Gas Liquids, Petroleum Products

November 9, 2009

Summary: Source Categories Not Yet Included

• EPA plans to further review public comments and other information before deciding on these subparts:– Electronics manufacturing– Ethanol production– Fluorinated GHG production– Food processing– Magnesium production– Oil and natural gas systems– Sulfur hexafluoride (SF6 ) from electrical equipment– Underground coal mines– Industrial landfills– Wastewater treatment– Suppliers of coal

• Facilities with these source categories could be covered by the rule based on GHG emissions from stationary fuel combustion sources.

JAMES D. SMITH 9

November 9, 2009

Summary of Rule: Critical Dates

1/1/2010Start collecting data. Best available monitoring

methods allowed

1/28/2010Submit request to extend use of best available

monitoring methods

3/1/2010 Utilize required monitoring methods

12/31/2010 Complete 2010 data collection

1/30/2011 Submit certificate of representation

3/31/2011 Submit GHG report for 2010

3/31/XXXX Submit annual reports in future years

JAMES D. SMITH 10

November 9, 2009

Global Warming Potential (GWP) or CO2e

• Global warming potential (GWP) is a metric used to compare varying heat-trapping ability and atmospheric lifetimes of GHGs.

• The GWP of CO2 is 1.0, and the GWP of other GHGs are expressed relative to CO2– For example, CH4 has a GWP of 21. Each metric ton

of CH4 emissions would have 21 times as much impact on global warming (over a 100- year time horizon) as a metric ton of CO2 emissions.

• Mass emissions x GWP = CO2 e (metric tons)Table A-1 (p. 56395 of Federal Register) lists

GWPs

JAMES D. SMITH 11

November 9, 2009

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 CO2 e or more per year

• Manure Management Systems with combined CH4 and N2 O emissions in amounts equivalent to 25,000 metric tons CO2 e or more per year.

JAMES D. SMITH 13

November 9, 2009

Table 2: Threshold Source Categories

• Ferroalloy Production• Glass Production• Hydrogen Production• Iron and Steel Product

ion

• Lead Production• Pulp and Paper Manu

facturing• Zinc Production

Report if ≥ 25,000 metric tons CO2e per year from all source categories, combustion units, and miscellaneous use of carbonates.

JAMES D. SMITH 14

November 9, 2009

Table 3: Stationary Combustion Units

• Boilers• Stationary Internal Combustion Engines• Process Heaters• Combustion Turbines• Incinerators• Other Stationary Fuel Combustion

Equipment

Report if aggregate maximum rated heat input capacity ≥ 30 mmBtu/hr and ≥ 25,000 metric tons CO2e per year from all source categories, combustion units, and miscellaneous use of carbonates.

JAMES D. SMITH 15

November 9, 2009

ExclusionsSource Category does not include:• Portable Equipment• Emergency generators and emergency equipment• Irrigation pumps at agricultural operations• Flares (unless required by another subpart)• Electricity generating units not subject to subpart D • Hazardous waste combustors do not report unless:

– CEMS is used to quantify CO2 or

– Table C-1 fuel is also combusted (then only report emissions from C-1 fuel)

JAMES D. SMITH 16

November 9, 2009 JAMES D. SMITH 17

Related Issues:Relationship with State Programs

• This rule does not preempt states from regulating or requiring reporting of greenhouse gases

• Data collection will not be delegated to state agencies

• Reporting will be directly to EPA through a web-based data system. EPA is working with states, The Climate Registry and the Exchange Network on a data exchange standard for GHG reporting.

November 9, 2009 JAMES D. SMITH 18

Related Issues: Mobile Sources

• Manufacturers of new vehicles and engines outside of the light-duty sector must provide emissions rate information for greenhouse gases (GHG).

• It also requires upstream suppliers of petroleum products and coal-based liquid fuels to report.

• Facilities are not required to report emissions from

mobile sources at their operations such as fleets. • EPA/NHTSA have proposed a comprehensive light-duty

GHG emission control program commencing in model

year (MY) 2012.

November 9, 2009 JAMES D. SMITH 19

Related Issues: Related Climate Change Action

• Endangerment Finding (Massachusetts v. EPA)• Proposed Tailoring Rule: Would Apply To GHG

Under Prevention Of Significant Deterioration (PSD) And Title V

• Permitting: Reconsideration Of The 12/18/08 Johnson CO2 Memo

• Geologic Sequestration Rule • Proposed Rulemaking: Implications Of

Endangerment Finding For Regulating GHG Emissions

• Cap And Trade Legislation

November 9, 2009 JAMES D. SMITH 20

Additional Information• EPA’s Regulatory Initiatives On Climate Change:

– http://www.epa.gov/climatechange/initiatives/index.html• GHG Mandatory Reporting Rule Website:

– http://www.epa.gov/climatechange/emissions/ghgrulemaking.html• GHG MRR Training Opportunities:

– http://www.epa.gov/climatechange/emissions/training.html• GHG MRR Overview Presentation: (32 pp)

– http://www.epa.gov/climatechange/emissions/downloads/FinalMRROverview.pdf

• GHG MRR Detailed Presentation (74 pp):– http://www.epa.gov/climatechange/emissions/downloads09/Webinar_Gen

eral_Overview.pdf• GHG MRR Information Sheets For Source Categories

– http://www.epa.gov/climatechange/emissions/ghg_infosheets.html• GHG MRR Hotline:

1-877-GHG-1188

November 9, 2009 JAMES D. SMITH 21

Contact Information

Contact Jim Smith:– Email: smith.james-d@epa.gov– Phone: (215) 814-2197