by Brittany Zwicker, Second Nature Intern

On September 22, 2009, the United States Environmental Protection Agency’s Administrator Lisa Jackson signed their Mandatory Reporting of Greenhouse Gases Rule. This is the final version of the proposed rule we alerted you to in the April issue of The ACUPCC Implementer (EPA Proposes National Reporting of GHG Emissions).

The new rule will go into effect on January 1, 2010 and the first reports will be due on March 31, 2011, reflecting emissions from the 2010 calendar year. The rule will require reporting by all facilities that release annual emissions of 25,000 metric tons CO2 equivalent (25,0000 mtCO2e), and the data reported will reflect 85% of all emissions in the United States. Similar to the ACUPCC’s transparent reporting system, the emissions reported to the EPA will be publicly posted.

As of October 2009, the ACUPCC has collected 719 greenhouse gas emissions inventories from 448 higher education institutions. Since many of the ACUPCC signatory schools already know their baseline GHG emissions, it will make it much easier for them to determine if they have to report. An analysis of the reports shows that approximately 60 ACUPCC signatories of the 448 that have already submitted GHG reports may have to report to the EPA.

Bob Koester, Implementation Liaison at Ball State University, says he believes that being a signatory to the ACUPCC places his school in a very good position for reporting to the EPA. They already have documentation of their GHG emissions and know that they will have to report. The EPA regulation may also assist the ACUPCC committee at Ball State in getting their Climate Action Plan approved. “We plan to talk about the EPA’s regulation when we present our Climate Action Plan to our president next month, to demonstrate that we are ahead of the curve in reducing our emissions and to gain support for our plan,” he said.

Although the rule has required reporting from certain emissions sources (i.e. cement or aluminum plants), the area most likely to be relevant to college or university campuses is the requirement for emissions from stationary fuel combustion equipment or boilers. In these cases, the details of the rule require reporting based on a single facility’s emissions. A facility is defined in the rule as “as any physical property, plant, building, structure, source, or stationary equipment located on one or more contiguous or adjacent properties in actual physical contact or separated solely by a public roadway or other public right-of-way and under common ownership or common control, that emits or may emit any greenhouse gas.” At Ball State for example, the electricity generating heat plant and all of its associated components are located in a central location on campus, constituting one “facility.” Conversely, at the University of Kentucky (not a signatory school), there are two coal-fired power plants at different ends of campus. In this case, the university will have to figure out the emissions from each plant to see if either emits more than the 25,000mtCO2e threshold.

For assistance in determining if your school will have to report, the EPA has released a table model with descriptive guidance and a more in-depth Applicability Tool for just that purpose. If you determine that you do have to report, be aware that the information the EPA requires might be different than that required by the ACUPCC. Also, since the reporting requirements are based on annual emissions, the EPA recommends that even if a facility is emitting less than 25,000mtCO2e at the beginning of a particular year, an institution should begin tracking emissions through the year to ensure that by December the facility has not exceeded the reporting requirement threshold. There is also an incentive for facilities to reduce their emissions built in to the rule. The EPA explains, “Once subject to this reporting rule, reporters must continue to submit GHG reports annually. A reporter can cease reporting if the required annual GHG reports demonstrate that reported GHG emissions are either (1) less than 25,000 metric tons of CO2e per year for five consecutive years or (2) less than 15,000 metric tons of CO2e per year for three consecutive years.”

For more technical information and answers to specific questions, the EPA has released a fairly extensive list of Frequently Asked Questions to accompany the rest of the documents collected on the issue. ACUPCC signatories might also be interested in the EPA’s annual Inventory of U.S. Greenhouse Gas Emissions and Sinks Report (Inventory) which is a top-down assessment of the all of the emissions in the country.