Voluntary Programs and Mandated Actions

Susan WickwireEnergy Supply & Industry BranchOffice of Atmospheric Programs

March 23, 2010

Chronology of Voluntary and Mandatory Programs

• Green Lights/ENERGY STAR – launched early 90s

• Methane capture programs (e.g., landfills, coal mines) – mid 90s

• Climate/clean energy programs (e.g., Climate Leaders, CHP Partnership, Green Power Partnership) - 2001-2002

• Mandatory GHG Reporting rule finalized – 2009

• Release of proposed GHG stationary source permitting rule - 2009

Climate Leaders

• Climate Leaders works with organizations to develop a long-term comprehensive GHG management strategy

• Road-tested with ~ 200 partners from every major sector across the country, representing 8% U.S. emissions and 12% U.S. GDP

– Increase in participation as mandatory approaches became more likely

• 3 critical components to credible strategy:– 1) Complete Corporate-Wide GHG Inventory – 2) Develop Inventory Management Plan (IMP)– 3) Set Aggressive Corporate-Wide GHG Reduction Goal

• Helped establish standards for reporting and increased corporate awareness and action during previous Administration

• Valuable role to play before mandated actions are implemented and potentially after

Mandatory Reporting Rule (MRR)

• Emissions-based threshold of 25,000 metric tons of CO2e per year for most sources (other than mobile sources)

• Opt-out options for facilities that fall below the threshold

• Approx. 85% of total U.S. greenhouse gas emissions covered by rule (about 10,000 reporters)

• Data collection began January 1, 2010 with first reports submitted to EPA March 31, 2011

• Self-certification with EPA verification• Mobile sources - reports from fuel suppliers and

makers of vehicles and engines (outside of the light-duty sector)

No requirements for fleet operators

Climate Leaders and the MRR

• Participation in CL prepared high-emitting Partners for future mandatory reporting

• CL staff participation in internal MRR workgroups to develop rule

• Overlap between CL and MRR limited to large direct emissions – important role for CL in reducing Scope 2 emissions

• Coordination between CL and MRR – outreach efforts to relevant groups

• MRR contributes to transparency of all companies’ GHG inventories

Permitting for Stationary Sources – “GHG Tailoring Rule”

• Proposes to raise the “major source” thresholds and PSD “significance levels”– PSD and Title V: major source size raised to 25,000 tons/year

CO2e (sum of 6 gases)– PSD significance level: raised to a number within the range of

10,000-25,000 tons/year CO2e (sum of 6 gases)– Proposal took comment on other levels

• Facilities above these levels would still be required to obtain permits– Facilities that remain covered are responsible for nearly 70 percent

of stationary source GHG emissions– Facilities proposed for exclusion comprise only 7 percent

• Small farms, restaurants, office buildings, etc. would not need to get permits

• February letter from Administrator Jackson to U.S. Senators sheds additional light on EPA approach

Other Climate Leaders Policy-Related Actions

• Testing ground for EPA offsets approach

• Provided technical assistance to carbon labeling provisions in H.R. 2454

• Participating in USG effort to inventory GHG emissions and set goals