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In this advisory, Partner Gabrielle Sigel and Associate Jennifer L. Cassel discuss the Obama administration's first major regulatory action on greenhouse gas (GHG) emissions. On September 22, 2009, U.S. EPA issued a final rule imposing mandatory reporting of greenhouse gas (GHG) emissions. The rule requires most sources to submit their first annual GHG emission report on March 31, 2011, covering emissions for the calendar year beginning January 1, 2010. According to the advisory, EPA estimates that the rule will cover 85% of total U.S. GHG emissions from approximately 10,000 facilities, and is expected to cost approximately $115 million the first reporting year and $72 million each subsequent year.