The EPA made a few minor changes to its greenhouse gas (GHG) reporting regulation, mostly to clean up language, but the Friday, Dec. 17, 2010, Federal Register notice included a buried requirement that could have a big effect for companies responsible with biogenic CO₂ emissions.

The agency amended various subparts in Part 98 to correct errors in the regulatory language that were identified as a result of working with reporters to implement the various subparts of Part 98. The agency also amended certain rule provisions to provide greater clarity. The amendments to Part 98 include the following types of changes:

• Additional information to understand better or more fully compliance obligations in a specific provision, such as the reference to a standardized method that must be followed.
• Amendments to certain equations to better reflect actual operating conditions.
• Corrections to terms and definitions in certain equations.
• Corrections to data reporting requirements so that they more closely conform to the information used to perform emission calculations.
• Amendments, in limited cases, to allow for the use of simplified emissions calculation methods.
• Changes to correct cross references within and between subparts.
• Other amendments related to certain issues identified as a result of working with reporters during rule implementation and outreach.
• Applying a threshold for reporting for local distribution companies of equal to or greater than 460,000 thousand standard cubic feet (mscf) of natural gas delivered per year.
• Requiring separate reporting of biogenic CO₂ emissions for units that are also subject to 40 CFR part 75, beginning with the 2011 reporting year.

The one new requirement, regarding reporting of biogenic CO₂ emissions from units subject to 40 CFR Part 75, is being phased in, so that it remains optional for reporting year 2010, but becomes mandatory for each subsequent year.

The agency noted in its release that (emphasis ours) "several commenters requested that we make use of the amendments optional for the 2010 reporting year and mandatory beginning with the 2011 reporting year. The commenters expressed concern that in 2010, sources may not have been collecting the required data to implement certain amendments." These comments echo fears that many readers of PE have expressed, and also the results of informal polling at 2010 conferences like EUEC. The agency seems to moving ahead with its reporting requirements regardless.

SOURCE: Federal Register