Let the Reporting Begin: USEPA's Mandatory Greenhouse Gas Reporting Rule

On September 22, 2009, the U.S. Environmental Protection Agency issued its Mandatory Greenhouse Gas (GHG) Reporting Rule, which will require over 10,000 U.S. facilities to report their GHG emissions annually. The Rule generally applies to facilities that emit more than 25,000 metric tons of carbon dioxide equivalent (mtCO₂e) or more per year, although some sources with lower emissions in specific sectors of the economy will also be subject. Recordkeeping and reporting requirements are significant and will warrant processes to ensure a consistent, defensible approach. The article discusses the background, purpose, and organization of the Rule; applicability, emissions accounting, reporting, recordkeeping, and emission verification; and presents a potential implementation plan.