Mandatory Greenhouse Gas Reporting

Cotter, David
(Capaccio Environmental Engineering, Inc.)

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Two landmark regulations were passed in 2009 related to mandatory reporting of greenhouse gas (GHG) emissions. In July, the Massachusetts Department of Environmental Protection (MassDEP) published its final GHG reporting rule (310 CMR 7.71) and in October the United States Environmental Protection Agency (EPA) published its final Mandatory Reporting of Greenhouse Gases Rule (40 CFR Part 98). While these two regulations are similar in what they require for reporting, they are dissimilar in their applicability thresholds and what entities are affected. The MassDEP regulation has an applicability threshold of 5,000 short tons and applies to all GHG emitters, while the EPA threshold is set at 25,000 metric tons and is only applicable to certain industry sectors and fuel combustion sources. The semiconductor sector is covered by the MassDEP regulation but it was removed from the final EPA regulation as an affected source category (it was originally included in the EPA draft rule). Semiconductor facilities that operate large fuel combustion units could still be affected by the EPA rule, however. The reporting due date for facilities affected by the MassDEP regulation is April 15, 2010, while the EPA reporting due date is March 31, 2011. This presentation will summarize how the MassDEP and EPA regulations affect semiconductor manufacturing facilities, the methods used to determine applicability of the regulations, and the methods for reporting GHG emissions. The focus for the EPA rule will be a description of how large general stationary fuel combustion sources are required to be reported under the rule. For the MassDEP regulation the discussion will be on how to utilize The Climate Registry’s General Reporting Protocol (GRP) v.1.1 to quantify GHG emissions. In particular, the discussion will describe GRP methodologies for fuel combustion, mobile sources, and semiconductor manufacturing.

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