EPA clarifies GHG reporting confusion

By Kris Bevill | November 11, 2009
Report posted Nov. 19, 2009, at 4:44 p.m. CST

On Nov. 19, the U.S. EPA held a detailed training session to explain its recently finalized greenhouse gas (GHG) reporting rule and attempted to clarify some of the confusion surrounding the ethanol industry's required participation in the rule.

Both the Renewable Fuels Association and Growth Energy submitted questions prior to the session. Questions were accepted from participants during the training as well. The majority of questions from ethanol producers focused on ethanol as a source category, the use of flow meters to measure GHGs and how carbon dioxide will be required to be measured.

The EPA confirmed that, while ethanol was exempted as a source category from its final rule, any producer that emits more than the 25,000-ton-per-year threshold of carbon dioxide equivalent (CO2e) will be required to participate in the EPA's reporting program. Additionally, the EPA will continue to review the 11 source categories left out of its final rule, including ethanol, and it intends to include those source categories in the future. The agency warned that it expects to make several rule makings in 2010 that will address these individual reporting groups. Revisions to the list of required reporters won't take effect until 2011, so companies should be aware that if they are not affected by the reporting rule in 2010, they will need to reassess the rule for the next year.

Several questions were posed to the EPA on the use of flow meters as a method of calculating GHG emissions. While all emissions from stationary combustion sources must be accounted for, EPA officials confirmed that there are provisions in the rule that allow standard billing meters to be used to determine the amount of gas used and GHG emissions can be calculated based upon those readings. Because of that provision, producers won't be required to install flow meters on every stationary gas source, because the billing meter will measure the intake of gas.

During the session, the EPA provided calculations that determine what stationary combustion units will emit 25,000 tons of CO2e annually. Trigger amounts for various units include: a coal-fired unit that uses 10,800 tons of fuel annually, a fuel oil unit that uses 2.3 million gallons of fuel annually, or a natural gas unit that consumes 460 million cubic feet of fuel annually.

Direct emissions of CO2 into the atmosphere as a result of the ethanol fermentation process will not have to be reported, according to EPA officials at the training session. There is no methodology for reporting emissions from fermentation, so the only instance in which a producer would be required to report those emissions would be as a supplier of CO2—either via sequestration or by transferring it to a facility off-site. If the ethanol producer utilizes the CO2 for an on-site process, it will not be required to include those CO2 emissions in its report.

As for the schedule for monitoring and reporting GHG emissions, participants will be required to begin collecting data using best available monitoring methods on Jan. 1. The deadline for submitting applications to extend the use of those methods is Jan. 28. By March 31, all participants must begin using the required monitoring methods, with the exception of those that were granted extensions. Data collection must be complete at the end of 2010; certificated of representation need to be filed with the EPA by Jan. 30, 2011; emissions reports for 2010 are due on March 31, 2011.

An outline of the information presented during the training session can be viewed at http://www.epa.gov/climatechange/emissions/downloads09/Webinar_General_Overview.pdf.