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EPA Proposes Mandatory Reporting on Greenhouse Gas Emissions

Apr 06, 2009

The U.S. Environmental Protection Agency will propose a rule on Friday, April 10, that will establish a national system for reporting emissions of carbon dioxide and other greenhouse gases from approximately 13,000 sources. The new requirements would apply to a variety of industries, including dairy processing, dairy production, utilities and other manufacturers with emissions that equal or exceed a threshold of 25,000 metric tons per year.

The rule focuses on direct emissions, not indirect emissions, such as those associated with electricity, and it does not include emissions associated with mobile sources, such as trucks. The threshold will apply to levels of carbon dioxide and methane and nitrous oxide (on an equivalent basis) from a single facility or source.

In collaboration with its Environmental Worker Safety (EWS) Committee, IDFA has concluded that the vast majority of dairy processors will not be subject to reporting under this rule. IDFA estimates that a facility would need to combust approximately 450,000,000 cubic feet of natural gas or burn approximately 2,400,000 gallons of distillate fuel in order to reach the proposed threshold.

In addition to greenhouse gas emissions from stationary combustion sources, food processors also will be required to report emissions from onsite landfills and anaerobic wastewater treatment systems. Dairy processors, however, do not have onsite landfills, and the rule will exempt combusted methane produced in an anaerobic digester because the methane does not become an emission. EPA also will exempt the carbon dioxide emissions that result from the combustion of anaerobic digester gas.

With respect to dairy production, EPA estimates that fewer than 50 of the largest livestock operations, including dairy farms, would meet the threshold based on emissions from their manure management systems.

If the rule is finalized, the first reports would be required in 2011, and they would include data on greenhouse gas emissions during 2010.

IDFA is reviewing the more than 1,400 pages included in the rule package and will consider submitting comments after discussing the rule's implications with its Environmental Worker Safety Committee. EPA will hold a 60-day comment period following the rule's publication in the Federal Register. The agency also is holding public hearings today and tomorrow in Arlington, Va., and on April 16 in Sacramento, Calif.

A pre-publication version of the rule package is available here. Members with questions about the proposed rule or the industry's efforts to reduce greenhouse gas emissions may contact Clay Detlefsen, IDFA vice president of regulatory affairs, at (202) 220-3554 or


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