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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): Major Sources and Major Stationary Sources of greenhouse gas (GHG):


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

Carbon Dioxide Equivalent

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: