Voluntary Programs and Mandated Actions Susan Wickwire Energy Supply & Industry Branch

1. Voluntary Programs and Mandated Actions Susan Wickwire Energy Supply & Industry Branch Office of Atmospheric Programs March 23, 2010

2. Chronology of Voluntary and Mandatory Programs • Green Lights/ENERGY STAR – launched early 90s • Methane capture programs (e.g., landfills, coal mines) – mid 90s • Climate/clean energy programs (e.g., Climate Leaders, CHP Partnership, Green Power Partnership) - 2001-2002 • Mandatory GHG Reporting rule finalized – 2009 • Release of proposed GHG stationary source permitting rule - 2009

3. Climate Leaders • Climate Leaders works with organizations to develop a long-term comprehensive GHG management strategy • Road-tested with ~ 200 partners from every major sector across the country, representing 8% U.S. emissions and 12% U.S. GDP • Increase in participation as mandatory approaches became more likely • 3 critical components to credible strategy: • 1) Complete Corporate-Wide GHG Inventory • 2) Develop Inventory Management Plan (IMP) • 3) Set Aggressive Corporate-Wide GHG Reduction Goal • Helped establish standards for reporting and increased corporate awareness and action during previous Administration • Valuable role to play before mandated actions are implemented and potentially after

4. Mandatory Reporting Rule (MRR) • Emissions-based threshold of 25,000 metric tons of CO2e per year for most sources (other than mobile sources) • Opt-out options for facilities that fall below the threshold • Approx. 85% of total U.S. greenhouse gas emissions covered by rule (about 10,000 reporters) • Data collection began January 1, 2010 with first reports submitted to EPA March 31, 2011 • Self-certification with EPA verification • Mobile sources - reports from fuel suppliers and makers of vehicles and engines (outside of the light-duty sector) • No requirements for fleet operators

5. Climate Leaders and the MRR • Participation in CL prepared high-emitting Partners for future mandatory reporting • CL staff participation in internal MRR workgroups to develop rule • Overlap between CL and MRR limited to large direct emissions – important role for CL in reducing Scope 2 emissions • Coordination between CL and MRR – outreach efforts to relevant groups • MRR contributes to transparency of all companies’ GHG inventories

6. Permitting for Stationary Sources – “GHG Tailoring Rule” • Proposes to raise the “major source” thresholds and PSD “significance levels” • PSD and Title V: major source size raised to 25,000 tons/year CO2e (sum of 6 gases) • PSD significance level: raised to a number within the range of 10,000-25,000 tons/year CO2e (sum of 6 gases) • Proposal took comment on other levels • Facilities above these levels would still be required to obtain permits • Facilities that remain covered are responsible for nearly 70 percent of stationary source GHG emissions • Facilities proposed for exclusion comprise only 7 percent • Small farms, restaurants, office buildings, etc. would not need to get permits • February letter from Administrator Jackson to U.S. Senators sheds additional light on EPA approach

7. Other Climate Leaders Policy-Related Actions • Testing ground for EPA offsets approach • Provided technical assistance to carbon labeling provisions in H.R. 2454 • Participating in USG effort to inventory GHG emissions and set goals