Jenner & Block

Client Advisory: U.S. EPA Proposes Mandatory Greenhouse Gas Emission Reporting Rule

In this client advisory Partner Gabrielle Sigel and Associate Michael R. Strong discuss the long-awaited release by the U.S. EPA of a proposed rule for mandatory reporting of greenhouse gas (GHG) emissions.  The proposed rule, which was Congressionally mandated in an appropriations bill signed by President Bush in late 2007, would require the first annual GHG emission report to be submitted on March 31, 2011, covering emissions for the calendar year beginning January 1, 2010.  EPA estimates that its rule will cover 85-90% of total U.S. GHG emissions, from approximately 13,000 facilities.  Comments on the proposed rule must be submitted 60 days after the Draft’s publication in the Federal Register.  Public hearings will be held on April 6 and 7, 2009, in Washington, D.C., and on April 16, 2009, in Sacramento, California.