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Federal Greenhouse Gas Regulations

Reporting Greenhouse Gas Emissions

Large emitters of greenhouse gases (GHG) are required by the U.S. Environmental Protection Agency (EPA) to collect greenhouse gas (GHG) emissions data under a national reporting system. The reporting covers approximately 85 percent of the nation’s greenhouse gas (GHG) emissions and 10,000 facilities. This reporting rule is called the Mandatory Reporting of Greenhouse Gases Rule, promulgated in October 2009.

Permitting of Greenhouse Gas Emissions

Additionally, large stationary sources of greenhouse gas (GHG) are required under the Prevention of Significant Deterioration (PSD) and Title V Operating Permit programs to obtain permits for construction or operation of their facilities effective January 2, 2011. The U.S. Environmental Protection Agency (EPA) has estimated that this will affect an additional 550 facilities nationwide, up to 15,550 in total. This permitting related rule is called the Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule, promulgated in June 2010, and commonly called the Tailoring Rule.

The following table is a side-by-side comparison of these two rules.

RULE	Mandatory Reporting of Greenhouse Gases Rule (MRR)	Prevention of Significant Deterioration and Title V Greenhouse Gas (GHG) Tailoring Rule
Administrator	U.S. Environmental Protection Agency (EPA)	Air Pollution Control Division (APCD), Colorado Department of Public Health and Environment
Intention of Rule	Reporting of actual greenhouse gas (GHG) emissions: No control requirements No emissions limitations No applicable requirements No permitting requirements	Permitting potential to emit of greenhouse gas (GHG): Potential for Prevention of Significant Deterioration (PSD) Review / Best Available Control Technology (BACT) limits Title V Operating Permits required No minor source permitting No minor source reporting
Thresholds	25,000 metric tons per year (mtpy) CO2e for certain source categories All-in for others	Title V – major source	100,000 tons per year (tpy) CO2e and 100 tons per year (tpy) greenhouse gas (GHG)
		Prevention of Significant Deterioration (PSD) – subject to regulation	100,000 tons per year (tpy) CO2e and 100/250 tons per year (tpy) greenhouse gas (GHG)
Affected Sources	Sources of greenhouse gas (GHG): Environmental Protection Agency (EPA) Website	Major Sources and Major Stationary Sources of greenhouse gas (GHG): Air Quality Control Commission Regulation (AQCC) No. 3

Greenhouse gas (tons per year mass) x Global Warming Potential = Greenhouse gas (tons per year CO2e)
Greenhouse Gases (GHG)	CO2	Carbon Dioxide
	CH4	Methane
	N2O	Nitrous oxide
	HFCs	Hydrofluorocarbons
	PFCs	Perfluorocarbons
	SF6	Sulfur hexafluoride
Global Warming Potential (GWP)	40 C.F.R. Part 98, Subpart A, Table A-1: Global Warming Potentials (74 FR 56395-56396)
Carbon Dioxide Equivalent (CO2e)	Carbon dioxide equivalent means a metric used to compare the emissions from various greenhouse gas classes based upon their global warming potential (GWP).

For additional information on these regulations, please refer to the following links: