EPA Seeks Comment on Draft Greenhouse Gas Report

On March 7, 2008, EPA published a Notice of Document Availability and Request for Public Comments on its "Draft Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006".  The final Report will be the latest in a series of annual submittals by the United States to the Secretariat of the United Nations Framework Convention on Climate Change.  The data and methodologies used in the Report, when finalized, will also very likely influence the substance of EPA's greenhouse gas reporting rules, which EPA is required to promulgate by June 26, 2009 (see the Holland & Hart Climate Change Law Blog post dated February 14, 2008, for more information on the GHG reporting rules).  The EPA reporting rules in turn are expected to influence the reporting requirements under a mandatory greenhouse reduction program when such a program is eventually enacted by Congress.  The Draft Report is organized according to source categories and sectors, including energy, industrial processes, solvent use, agriculture, land-use change and forestry, and waste.  There is also the ubiquitous "other" category.

The Draft Report contains estimates of various greenhouse gas emissions and "carbon fluxes" or carbon sinks and releases in U.S. agricultural and forest lands.  The full Draft Report can be downloaded here.

Comments on the Draft Report are due within 30 days of the date of the Federal Register Notice, or April 6, 2008 (although given that April 6 is a Sunday, presumably the comment period would actually close on April 7).

Companies that anticipate being subject to EPA's forthcoming GHG reporting regulations and future mandatory cap-and-trade or other GHG reduction programs should consider reviewing and commenting on the Draft Report.