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EPA Issues Final Mandatory Reporting Rule for Greenhouse Gas Emissions

Sep 28, 2009

The U.S. Environmental Protection Agency last week announced its final rule for mandatory reporting of greenhouse gas emissions. The new requirements 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 inclusion of dairy is based solely on the combustion of fuels and the emissions from that activity, according to Clay Detlefsen, IDFA vice president of regulatory affairs.

The rule establishes a national system for collecting information on emissions of carbon dioxide and other greenhouse gases from approximately 10,000 facilities. It 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.

EPA will require the first reports to be submitted in 2011 with details on all 2010 emissions. The agency is holding a series of webinars for affected companies, including one this week on September 30, 1:00 - 3:00 p.m. Eastern time. A schedule of October sessions is available here.

The final rule package is available here . Members with questions about the 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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