First steps toward permitting of greenhouse gas emissions from stationary sources

Among arguments set forth in support of passage of a “cap and trade” bill to regulate emissions of carbon dioxide and other greenhouse gases from power plants, manufacturers and other stationary facilities is “if Congress doesn’t do it, the Administration will,” under rulemaking authority already granted via the Clean Air Act and its amendments.

Well, yes…

On September 30, the Environmental Protection Agency (EPA) announced two proposals that will advance control of greenhouse gas emissions through existing regulatory frameworks. The first of these will determine when regulatory action triggers applicability of the Prevention of Significant Deterioration (PSD) program to air pollutants, such as carbon dioxide and other greenhouse gases. The second proposal establishes “tailored” thresholds for applying New Source Review and Title V Operating Permit requirements to emissions of greenhouse gases from large facilities. 

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Compliance Tip of the Week: Defining your “facility” for SPCC Plan requirements

The November 2008 amendments to Spill Prevention, Control and Countermeasure (SPCC) Plan requirements provided facility operators with flexibility in defining the extent of the facility to be addressed in an SPCC Plan. This flexibility can be particularly helpful for large properties or installations, such as farms, multi-structured industrial plants and university campuses, where several buildings or locations may be used for storage and management of oil and other petroleum products.

The rule amendments redefined the term “facility” to allow the owner or operator to designate operations in or on contiguous or non-contiguous lands, properties, buildings and so forth as separate facilities for the purpose of compliance with the regulations. The owner or operator can aggregate or separate containers to determine the facility boundaries, and may determine that certain installations or parts thereof are effectively exempted from the rule if, for example, less than 1,320 gallons of oil are stored in aboveground containers within the boundaries of a designated “facility.”

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EPA issues rule requiring reporting of greenhouse gas emissions

And so it begins…

The Environmental Protection Agency on September 22 issued its Final Mandatory Reporting of Greenhouse Gases Rule.  Beginning with reporting year 2010, the rule will phase in requirements for annual reporting of greenhouse gas emissions from suppliers of fossil fuels or industrial greenhouse gases, manufacturers of vehicles and engines, and other facilities that may emit greenhouse gases in annual quantities of 25,000 metric tons or more.  Covered greenhouse gases include carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons and other fluorinated gases.

For more on the rule, including the published text, visit
For more information on greenhouse gases and climate change, visit or contact T. Cozzie Consulting Inc.