GHG Reporting Rule

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G 6.1 | Requirements and Developments in Environmental and Carbon Reporting and Disclosure

John Fillo | Senior Engineer, Sentech, Inc.

Climate change and carbon risk management are complex environmental and societal issues, as well as fundamental business issues. Increased reporting and disclosure of environmental and carbon exposures and liabilities, risks and opportunities are driven by federal, regional, and state/provincial requirements in the U.S. and abroad. These obligations are evolving from participation in voluntary initiatives to legislative- and regulatory-driven mandatory action. While reporting of greenhouse gas (GHG) emissions is only one component of these requirements, statutory financial disclosure requirements for publicly held companies extend these reporting obligations to address operations, business risks, legal and supply chain issues, as well as disclosures in financial statements. This presentation will provide an overview of and insight into the complexity of these requirements. It will summarize various mandatory and voluntary emissions reporting programs/requirements; outline statutory, industry and voluntary environmental and carbon disclosure requirements; address some of the complexities of carbon risk management that go beyond simply reporting a GHG inventory; and provide real-world examples of how selected entities approach conformance with these requirements. As the statutory requirements around GHG reporting, reductions, and overall carbon management expand and mature, so will the complexity of public reporting and disclosure.

G6.2 | An Inefficient and Costly Patchwork Quilt of GHG Reporting

Christina Schwerdtfeger | President, Coto Consulting, Inc.

This case study discusses the differences and similarities in mandatory greenhouse gas reporting programs between California, EPA and Executive Order 13514. The data collection and management challenges are substantial with very little consistency between reporting programs and tools.  The three-fold reporting burden on individual facilities is substantial but does not provide benefits which are commensurate with the level of effort. Using real data, this case study shows why a single regulatory and reporting framework makes sense.

G 6.3 | GHG Reporting Rule Requirements for Power Generating Units

Stephen Norfleet | Project Manager, RMB Consulting & Research, Inc.

Late in 2009, EPA promulgated the Mandatory Greenhouse Gas (GHG) Reporting Rule. The GHG reporting requires reporting of annual emissions of carbon dioxide (CO2) methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF6), hydrofluorocarbons (HFCs), perfluorochemicals (PFCs), and other fluorinated gases and affects over 30,000 individual facilities across some 40 source categories. The rule places additional monitoring and reporting requirements on sources and is likely to produce data that will influence potential GHG reduction policy decisions and could establish potential precedents for future CO2/GHG reporting requirements. The broadly reaching regulation will affect virtually all US generating units. With little time to prepare, sources were required to start monitoring in 2010 and will shortly need to submit the first electronic report by March 31, 2011 even though EPA has yet to release the final format. Complicating the issue, if a facility includes a GHG Reporting Rule affected source (boiler, turbine, etc.), then all combustion sources at the facility become affected (i.e., there is no “de minimis” exemption in the rule) including otherwise trivial overlooked sources (e.g., gas-fired hot water heaters or stoves) at the plant. The presentation will include: • Monitoring requirements and calculation procedures for combustion sources • Use of CEMS, fuel monitoring/analysis and/or options for using “company records” • Proposed requirements for electric transmission and distribution equipment (Subpart SS) • QA/QC requirements/equipment calibration and accuracy requirements •Reporting requirements (final reporting format expected in December 2010)

G 6.4 | The GHG Tailoring Rule Double-Take

Jamie Wilson | Senior Consultant, Trinity Consultants

The fanfare around EPA’s greenhouse gas (GHG) Tailoring Rule continues to focus primarily on the thresholds at which GHG emissions trigger the federal New Source Review (NSR) and Title V programs in 2011 and beyond. In addition, we have all heard of the subsequent EPA action focused on federal implementation of the rule in jurisdictions that were not poised to implement it to meet EPA’s timeframe. But look again! With regards to triggering the Prevention of Significant Deterioration (PSD) program, if your facility (especially a new facility!) triggers PSD for GHGs, the implications are significant, and this does not simply involve the uncertainty surrounding GHG BACT! This presentation will focus on the lesser-explored consequences of the Tailoring Rule on PSD permitting for both new facilities and modifications, as well as explore some interesting opportunities on how to navigate away from potential pitfalls and permitting traps.

G6.5 | NSR and GHG Emissions – A Regulatory Status Report

Dave Jordan | Air Program Director, ERM

The GHG Tailoring Rule is expected to have substantial impacts on the utility industry. This paper provides a brief overview of the rule and a report on the various challenges to its implementation including both FIP and SIP status updates.

G 6.6 | Electric Utility Small Project PSD Cautions post GHG Tailoring Rule

Brian Burdorf | Director, Trinity Consultants

Following U.S. EPA’s promulgation of the Tailoring Rule, electric utilities have to exercise increased sensitivity to the fact that the Prevention of Significant Deterioration (PSD) significance threshold for GHGs may be the most stringent PSD triggering threshold for certain projects. This presentation will discuss how seemingly minor upgrades (including projects affecting non-emissions generating equipment like steam turbines, heat transfer elements, cooling water systems, etc.) can encounter PSD permitting challenges. Based on several project examples, a comparison of the PSD threshold for GHGs with traditional criteria pollutant thresholds will be provided to identify if GHGs represent the triggering pollutant or not. A discussion of demand growth exclusion obligations for 5 to 10 years following a project will be provided for situations where projects do not trigger PSD based on the exclusion of emissions associated with product demand growth. The presentation content will draw upon recent project applicability analyses performed for electric utility generation facilities, court case precedents, and federal requirements.

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