As per the new Environmental Protection Agency regulations, facilities that produce in excess of 25,000 metric tons of greenhouse gas (GHG) emissions per year must begin to report their annual emissions to the EPA, effective January 1, 2010. Under this rule, only direct emissions occurring on the facility’s grounds are included in determining its total emissions; it will not include the facility’s indirect emissions resulting from electric generation at power plants supplying the facility. The regulation will not require the facility to reduce its emissions at this time, but the first annual emissions report covering the 2010 calendar year will be due by March 31, 2011. As the EPA collects these data over the next several years, the agency will decide on effective policies to mitigate greenhouse gas emissions.
This legislation includes emissions of the most common greenhouse gases, including carbon dioxide, methane, nitrogen dioxide, hydrofluorocarbons, petrofluorocarbons, sulfur hexafluoride (SF6), and other fluorinated gases, which have extremely high global warming potentials. Since the most powerful greenhouse gases, such as SF6, have global warming potentials that are ten or twenty thousand times as strong as carbon dioxide, only 1-2 tons of annual emissions of these gases can cause an industrial facility to exceed the mandatory reporting level.
The new rule will cover approximately 10,000 locations, including industrial gas suppliers, as well as electricity generation facilities, stationary fuel combustion sources, petroleum refineries, landfills, customers with high heating oil consumption, and heavy trucks and equipment. The EPA estimates that this program will cover 85% of U.S. greenhouse gas emissions. Most commercial buildings will not meet the minimum threshold that mandates emissions reporting, which is equivalent to the annual emissions of about 2,300 homes or that of 4,600 passenger vehicles. If a facility exceeds the emissions threshold of 25,000 tons of carbon dioxide equivalence during any given year, the facility owner or manager will be required to report annual emissions electronically to the EPA each year until the building can reduce its emissions below 25,000 tons for 5 consecutive years, or below 15,000 tons for 3 years.
In addition, building heaters such as water heaters that burn fuel qualify as a stationary fuel combustion source under the EPA’s definition. Therefore, they must be included in determining if the facility exceeds the emissions threshold of 25,000 tons, and must be included in any mandatory reporting. The EPA has posted a calculation tool on their website to help facilities determine their requirements under the regulation. If a commercial building has a maximum rate heat input capacity greater than 30 mmBtu per hour, the facility manager must complete further calculations to determine if it meets the threshold of mandatory reporting. Please visit the EPA’s GHG Mandatory Reporting Applicability Tool website to learn more information.
