Monday, October 18, 2010

Washington Proposed GHG Reporting Requirements

Washington has by statute adopted a Climate Change Framework that sets greenhouse gas(GHG) reduction targets over the next several decades. Ecology has been directed to develop and implement a reporting system to establish a baseline inventory of GHGs emitted in the state. Ecology began developing a GHG reporting rule before EPA’s reporting rules were available, and after the federal rules were released, the Washington legislature revised the state GHG reporting statute to be more in line with EPA’s reporting requirements. Ecology then worked to develop GHG reporting rules that would implement the revised state GHG reporting statute.

Ecology’s proposed rule requires the following sources to report emissions of certain GHGs:

• A single facility, source, or site that directly emits at least 10,000 metric tons of carbon dioxide equivalent gases (CO2e) annually in Washington; and
• Suppliers of liquid motor vehicle fuel, special fuel, or aircraft fuel that supplies products equal to at least 10,000 metric tons of CO2e annually in the state.

Ecology’s rule would also require reporting of emissions from biomass combustion sources. Facilities will not need to consider or report indirect emissions once they reach the threshold for direct emissions, which is a change from the draft rule released late last year. The proposed rule also does not require mobile sources such as cars, trucks, ships, trains, and planes to report because those emissions will be covered by fuel supplier reporting.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.

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info@calthacompany.com

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