On March 10, 2009, the U.S. Environmental Protection Agency (EPA) announced a proposed rule that would require mandatory reporting of greenhouse gas (GHG) emissions beginning in 2011 for virtually every industrial source category across the country. EPA will use the GHG emission data it collects in designing, implementing and enforcing future climate change programs, including a possible economy-wide cap and trade system. The first annual report would be due on March 31, 2011 for 2010 calendar year emissions, except for auto manufacturers, who would report on 2011 model year vehicles and parts. Interested parties will have 60 days to comment when the proposal is published in coming days.
Sidley Austin LLP and CRA International will host a teleconference on this proposed rule to address such questions as:
- Who will be subject to the rule, and which industrial sectors will be most impacted?
- What data and other information will have to be reported?
- What methodology will be used to measure and verify GHG emissions, and what new recordkeeping requirements will be imposed on businesses?
- What key issues should companies consider when drafting comments?
- What are the potential liabilities and risks associated with the rule and reporting GHG emissions, including the risk of enforcement?
- What are the organizational implications of complying with the rule, and how should companies be prepared organizationally for likely federal GHG regulation and/or legislation?
More information on the reporting rule is available at www.sidley.com/climatechange.
Christopher Bell, partner, Sidley Austin LLP
Maureen Crough, partner, Sidley Austin LLP
David Montgomery, Vice President, CRA International
Lee Kindberg, General Manager, Environment, Health & Safety, Maersk Inc.
Gene Tunison, Manager, Fuels Development and Policy Planning, ExxonMobil Refining
Moderator: Roger Martella, partner, Sidley Austin LLP and former General Counsel, U.S. Environmental Protection Agency
The teleconference will last approximately 90 minutes, and speakers will welcome questions. You will receive a dial-in number upon registering.
Wednesday, March 25, 2009
2:00 p.m. Eastern | 1 p.m. Central | 12 p.m. Mountain | 11 a.m. Pacific