12.16.2011 Greenhouse Gas (GHG) Reporting Deadline Extended For Some Facilities

Recently U.S. EPA amended specific provisions in the Mandatory Reporting of Greenhouse Gases Rule. Among the amendments was a “limited, one-time six month extension of the 2012 reporting deadline for facilities and suppliers that contain one or more source categories for which data collection began in 2011.” (76 Fed. Reg. 73886 (Nov. 29, 2011)). The amendment changed the GHG reporting deadline for twelve affected source categories from March 31, 2012, to September 28, 2012.

The deadline extension applies to any facility containing one or more of the following source categories: electronics manufacturing, fluorinated gas production, magnesium production, petroleum and natural gas systems, use of electric transmission and distribution equipment, underground coal mines, industrial wastewater treatment, geologic sequestration of carbon dioxide, manufacture of electric transmission and distribution, industrial waste landfills, injection of carbon dioxide, and imports and exports of equipment pre-charged with fluorinated GHGs or containing GHGs in closed-cell foams.

Originally, these new source categories would have been required to file their first GHG reports March 31, 2012, along with the original source categories. According to comments submitted to U.S. EPA, some facilities contain sources in multiple source categories and would be subject to two reporting deadlines in 2012. For this reason and others, U.S. EPA extended the GHG reporting deadline to September 28, 2012, for any facility who will also include in its annual GHG report for 2012 a source category for which data collection began in 2011.

Such a facility must log into the electronic-GHG Reporting tool (e-GGRT) by March 31, 2012, and submit a notification through e-GGRT that its facility is not required to report until September 28, 2012, for the 2011 reporting year.