Greenhouse Gas Reporting Deadline Looming

The first deadline for greenhouse gas (GHG) reporting (2010 emissions) is March 31, 2011. These reports are the first step in the creation of an inventory of greenhouse gas emissions generated by the most significant industrial and commercial sources. For this purpose (as described in our September 22, 2009, Environmental Alert), the Environmental Protection Agency (EPA) issued a final rule in October of 2009 mandating that approximately 10,000 covered entities begin collecting data on GHG emissions starting with calendar year 2010. While the recent change in the composition of Congress makes prospects of a nationwide cap-and-trade system unlikely for the foreseeable future, the GHG reporting rule remains in effect and the first round of reporting deadlines are just around the corner.