Posted On: October 8, 2008 by Tonkon Torp LLP

Oregon’s Proposed GHG Reporting Rules

Oregon’s proposed rules for mandatory greenhouse gas (GHG) emissions reporting were recently drafted by DEQ in response to a direct request from Governor Ted Kulongoski. The purpose of state-specific mandatory reporting is to provide a better understanding of the GHG sources in Oregon and to generate the data necessary to support the development of emission reduction strategies.

The reporting rules will apply to emissions of carbon dioxide (CO2), methane (CH4), nitrous oxide (N20), and sulfur hexafluoride (SF6), as well as, hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs). Direct emissions such as those from fuel combustion activities and/or process-related emissions and fugitive emissions will be required, but indirect emissions (i.e., fuel for automobile fleets) will initially be optional under the proposed rules. Oregon’s GHG reduction goals include arresting increasing emissions by 2010, reducing to 10% below 2005 levels by 2020, and reducing to 75% below 1990 levels by 2050. Sources with Title V Air Permits or Air Contaminant Discharge Permits (ACDP) would be required to report 2009 emissions under the new rules beginning in 2010. Beginning in 2011, non-air permitted sources including wastewater treatment plants, landfills, electric generating units, and electricity and natural gas transmission and distribution lines would be required to report 2010 GHG emissions.

DEQ plans to work closely with the Western Climate Initiative and The Climate Registry to ensure consistency with emissions calculation methodologies and reporting protocols. DEQ has approved GHG reporting protocols and emissions calculation tools provided by several other organizations including: WCI; Intergovernmental Panel on Climate Change; California Climate Action Registry; United States Environmental Protection Agency (EPA) Climate Leaders ; and the World Resources Institute.

DEQ originally requested that the Environmental Quality Commission adopt the proposed rules in August 2008. However, the schedule was subsequently extended so, the proposed rules will now be brought before the EQC in October 2008. On another note, the WCI just released its Design Recommendations for the WCI Regional Cap-and-Trade Program on September 23, 2008 and Essential Requirements of Mandatory Reporting for the WCI, Second Draft on September 30, 2008. Was DEQ’s decision to extend the original August 2008 deadline for adopting the rules related to the much anticipated set of final recommendations from the WCI? Regardless, the public and private sectors are eagerly awaiting news regarding the development of this significant state legislation considering the potential economic and environmental impacts.

Contributed by Integral Consulting Inc., a multi-disciplinary scientific consulting firm based in Mercer Island, Washington with offices in Portland, Oregon, Broomfield, Colorado, Annapolis and Berlin, Maryland, and Boston, Massachusetts. Scientists at Integral have the expertise to provide facilities with support for both GHG quantification and reporting. Contact Randi Wexler (rwexler@integral-corp.com) or Adam Bonin (abonin@integral-corp.com) in the Portland office (503-284-5545).

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