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EPA Issues Final Greenhouse Gas Monitoring and Reporting Rule by Scott D. Deatherage
Thompson & Knight LLP - Dallas Office
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October 27, 2009
Previously published on September 28, 2009
On September 22, 2009, the United States Environmental Protection Agency (the "EPA") issued its final greenhouse gas monitoring and reporting rule that will require as many as 10,000 facilities in the United States to measure their greenhouse gases ("GHGs") starting January 1, 2010, and start reporting them in early 2011 (the "GHG Reporting Rule"). Some industry groups had asked the EPA for a delay until 2011 to start monitoring and 2012 to start reporting their GHG emissions. The EPA chose not to provide such a delay and regulated facilities have only three and a half months to prepare for the monitoring that they must begin January 1, 2010. This may be particularly challenging for those companies that must install or modify continuous emission monitors ("CEMs").
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