Pennsylvania Expands Scope of Greenhouse Gas Reporting to Smaller Facilities
Posted: January 17th, 2013Author: All4 Staff
If you happen to be a facility located in Pennsylvania and are required to submit an Annual Inventory and Emission Statement to the Pennsylvania Department of Environmental Protection (PADEP) by March 1 of each year, you will likely receive the 2012 reporting notice in which PADEP informs that reporters must include greenhouse gas (GHG) emissions in their upcoming March 1, 2013 submittal.
We’ve spoken to PADEP and the new data is being requested due to GHG being considered “subject to regulation” under the Clean Air Act (CAA). Whether this brand new requirement will affect your facility is not at all dependent on whether or not your facility is subject to any Federal requirements for GHG due to exceeding a major source GHG threshold. In fact, a facility does not even have to be a major source subject to Title V to be required to report GHG to PADEP this year, since facilities with minor source State Only Operating Permits are receiving similar letters. It is also not dependent on whether you are subject to Federal reporting requirements under 40 CFR Part 98 (Mandatory Reporting of Greenhouse Gases). The requirement will apply to any facility located in Pennsylvania that is already required to submit an annual emissions inventory.
Until now, you may not have calculated GHG emissions due to falling below applicable 40 CFR Part 98 reporting thresholds, or not having gone through any permitting activities since GHG became subject to regulation. PADEP has attempted to alleviated some of this new burden for you by pre-populating your 2012 reporting forms to at least include placeholder fields for combustion-related carbon dioxide (CO2), nitrous oxide (N2O), and methane (CH4), thereby pointing out the most likely sources of GHG at your facility. PADEP also recommends utilizing 40 CFR Part 98 calculation methodologies to identify contributing sources of emissions and develop your corresponding calculations. However, it is important to note that PADEP’s recommendation to utilize 40 CFR Part 98 calculation methodologies does not include a recommendation to necessarily exclude emissions from sources that are exempted under 40 CFR Part 98 but included in your permit, or, on the contrary, to include sources of GHG emissions that are required under 40 CFR Part 98 but which are currently not included in your permit. PADEP is indicating that you must provide GHG data for all applicable sources of GHG that you currently report either combustion or process-related emissions for as part of your typical annual report.
Facilities that must now include GHG in their annual Pennsylvania report should reconsider their plans for preparing required submittals and adjust their schedules accordingly. If you haven’t previously calculated GHG emissions, you’ll want some extra time to identify appropriate equations, emission factors and operating data, and to do the additional math. If you need guidance, reach out to resources such as ALL4 well in advance of the deadline. On the other hand, if you are required to report your facility’s GHG at the Federal level by April 1, 2013, it will now behoove you to complete those calculations well in advance of the March 1 deadline for Pennsylvania so that you will be reporting consistently at both the State and Federal levels.