Some underground coal mine operators already saddled with
copious amounts of paperwork will soon be required to monitor and
report their greenhouse gas emissions. This week, the Environmental
Protection Agency ("EPA") signed a rule requiring that
four additional source categories track and report greenhouse gas
emissions under EPA's earlier GHG reporting rule published
October 30, 2009. Underground coal mines were originally excluded
from the 41 sources regulated in the 2009 rule, but will now be
required to report certain methane, carbon dioxide, and nitrous
oxide emissions when the rule becomes effective.
While surface mines, post-mining activities, and abandoned mines
are excluded from the rule, underground coal mines classified by
the Mine Safety and Health Administration ("MSHA") as
active, currently under development, or with active degasification
systems will be required to record and report emissions if they are
subject to MSHA's ventilation system sampling
