On March 10, 2009, EPA publicly released its proposed rule that would require mandatory reporting of greenhouse gas (GHG) emissions from all sectors of the economy. While this proposed rule would require reporting of emissions rather than emission controls, this rule is only the first step in a broad and expensive GHG regulatory program that will affect most U.S. industries. Future policies could include emissions standards, a carbon tax, or a cap-and-trade program.

The rule would require suppliers of fossil fuels and industrial GHGs; manufacturers of vehicles and engines; facilities containing certain source categories regardless of actual emission levels; and facilities that emit 25,000 metric tons per year of carbon dioxide equivalent GHG emissions or more to calculate and report GHG emissions to EPA on an annual basis.

EPA believes that approximately 13,000 facilities will meet the requisite thresholds and that the total national annualized compliance cost for the private sector for the first year is approximately $160 million and approximately $127 million for subsequent years. 

On March 10, 2009, EPA publicly released its proposed rule that would require mandatory reporting of greenhouse gas (GHG) emissions from all sectors of the economy. While this proposed rule would require reporting of emissions rather than emission controls, this rule is only the first step in a broad and expensive GHG regulatory program that will affect most U.S. industries. Future policies could include emissions standards, a carbon tax, or a cap-and-trade program.

The rule would require suppliers of fossil fuels and industrial GHGs; manufacturers of vehicles and engines; facilities containing certain source categories regardless of actual emission levels; and facilities that emit 25,000 metric tons per year of carbon dioxide equivalent GHG emissions or more to calculate and report GHG emissions to EPA on an annual basis.

EPA believes that approximately 13,000 facilities will meet the requisite thresholds and that the total national annualized compliance cost for the private sector for the first year is approximately $160 million and approximately $127 million for subsequent years.