What does the EPA's ruling mean for our clients?

25 September 2009

On September 22, 2009, the EPA finalized the nation's first comprehensive national system for reporting emissions of carbon dioxide (CO2) and other greenhouse gases (GHGs). The final rule requires monitoring to begin on January 1, 2010, with full compliance by April 1, 2010 (unless EPA grants a site-specific extension).

What changed in the final rule?
While some provisions of the final rule are consistent with the proposed rule, such as general applicability requirements, there are many important differences. A comprehensive evaluation of the rule requirements and gap filling measures must be accomplished in the few months remaining before the beginning of the reporting year.

What should I be doing now? 
Although just a start, the highest priority actions include:

  • Carry out a gap assessment against the rule requirements. This will include identification of all sources of GHGs, ensuring methods used are consistent with the rule, and that data management systems are adequate. The end result of the gap assessment is a compliance roadmap for quick implementation of rule requirements.
  • Determine if there are flow meters or other instruments that need to be installed before April 1, 2010; evaluate the ability to obtain and install the required instruments; and prepare an extension request if necessary.
  • Develop and put in place standards, procedures, and a written monitoring plan for collecting, quality assuring, and managing data, which will be required by 1 January.

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