On September 22, 2009 the U.S Environmental Protection Agency took its first step in regulating emissions of greenhouse gases by finalizing its Mandatory Greenhouse Gas Reporting Rule. The extraordinarily broad landmark program, which would require large emitters to begin collecting greenhouse gas data in 2010, is expected to cover approximately 85 percent of the nation’s greenhouse gas emissions from between 10,000 and 14,000 facility sources.
Next week, the Clean Air Act and greenhouse gas lawyers from McAfee & Taft will be teaming up with the air pollution regulatory and engineering experts from Cardinal Engineering to host a complimentary full-day seminar designed to assist businesses and facilities covered, or that could be covered, by the mandatory reporting rule to understand how to comply with these new reporting requirements.
The free seminar will held on Tuesday, October 13, from 8:30am – 5:00pm at the Presbyterian Health Foundation Conference Center in Oklahoma City.
The first half of the day, which is geared for company executives, in-house counsel and environmental and technical personnel, will provide a comprehensive overview of the rule, addressing such topics as the relation of the rule to national climate change efforts and state regional regulations programs, recordkeeping and reporting requirements, emissions verification, and compliance and enforcement.
The second half of the day will focus on specific technical application issues arising from the individual rules for each source category, particularly stationary fuel combustion as well as the three general categories of manufacturing, electricity and fuel suppliers, and waste management.
“Though we saw this mandatory reporting rule coming for a while now, the developments in the last month make this mandatory reporting rule even more important,” said Mary Ellen Ternes, the leader of McAfee & Taft’s environmental practice and co-chair of the Climate Change, Sustainable Development and Ecosystems Committee of the American Bar Association's Section of Environment, Energy and Resources. “Last month, EPA proposed Clean Air Act permits for major sources of greenhouse gases pursuant to two very expensive Clean Air Act permitting programs, the Prevention of Significant Deterioration Program and the Title V Operating Permit Program. Also, the recently released Kerry-Boxer Senate Bill (companion to Waxman-Markey Energy Bill) does not contain the same Clean Air Act PSD and Title V permit exemption that was included in the Waxman-Markey version. Reporting correctly pursuant to the new mandatory reporting rule is even more critical.”
”To be prepared to comply with this greenhouse gas reporting rule, affected emitters need to have a monitoring plan in place prior to January 1, 2010,” according to Steve Mason, president of Cardinal Engineering, Inc. and Oklahoma Department of Environmental Quality board member. “Many facilities will be required to perform periodic measurements, sampling, and measurement equipment calibrations above and beyond their current practices. Compliance with this rule cannot be postponed since the data gathering for emission calculations must begin on January 1, 2010.”
Additional participants include ODEQ and relevant trade groups, specifically Eddie Terrill, Air Quality Division Director with the ODEQ, and Ben Weinheimer of the Texas Cattle Feeders Association.
Interested participants can sign up online at www.mcafeetaft.com.