Last week the EPA released their proposed rule for greenhouse gas reporting. In true EPA form the preamble is 818 pages long… the proposed rule is 593 pages… and a summary here. The rule is the first step towards establishing a data set for a GHG regulatory system – the critical aspect being that the rule will require GHGs to be counted the same way that they (most likely) will be in a cap and trade system. This will provide a great set of baseline data for the regulatory targets.

Under the Bush Administration, the EPA released an Advanced Notice of Proposed Rulemaking for Regulating GHGs in July of 2008. The gist of the notice was to point out all the complexities and issues around regulating GHGs under the EPA’s Clean Air Act (CAA) – a brief summary and background can be found here. After reading this back in July, it was hard to see this recent push by the new Administration to continue under the CAA. 

The new Administration is also pushing forward with an endangerment finding for greenhouse gases – opening the door to regulating CO2 under the CAA. This leaked EPA document shows plans to have it done by Earth Day. 

For Canada… the U.S. is quickly catching up. An endangerment finding is a similar regulatory trigger as a ‘toxic’ finding under the Canadian Environmental Protection Act, 1999. So there’s likely 1-2 years before an agreement on a U.S. GHG regulation… probably 3-4 years before it becomes the law… in that time, Canadian businesses and citizens will need to have effective carbon management practices and policies in place to remain competitive – assuming Canada moves in step with the U.S. 

Things are moving quickly… but for how long? Either way, a price on carbon is a price on carbon… no matter if its a tax or a cap and trade system, things with carbon in them or that emit carbon when built/refined/transported will cost more… are you ready for it?


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