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On December 17, 2007, a DEQ advisory committee was to make its recommendations concerning how reporting of Greenhouse Gas (GHG) emissions should be handled in Oregon. Notwithstanding advocacy for broader-based reporting, the recommendations limit those who would need to report. Based on the December 10 discussion draft, the committee recommended the following.

Air Permits. Any entity with a Federal Title V permit (TV) or a state Air Contaminant Discharge Permit (ACDP) would be required to report (about 1200 facilities).

Electricity producers. All electric utilities, power wholesalers, self-generating customers and electric service suppliers would report emissions.

Other energy facilities. Natural gas utilities, interstate pipelines and propane and fuel oil distributors would report products sales and natural gas transport volumes.

Locations. At this point only facilities located in Oregon would report.
Commencement. Reporting would be for the year 2009 and reports would be made near the beginning of 2010.

Methods. The protocols of the Climate Registry (now 39 states) would be followed generally, but actual reporting would be made to DEQ. DEQ would then pass the information along to the Climate Registry.

Permits. Rather than re-open each permit, DEQ would issue a general permit with the reporting requirements in it.

Verification. Rather than required third-party verification, DEQ would rely on self-certification with periodic DEQ inspections.

Review. When the cap and trade system is more clearly understood, DEQ would need to review the reporting rules.

Mobile Sources. While voluntary reporting by entities with existing fleets was suggested, the committee recommended collection of fuel consumption, vehicle miles traveled (VMT), and vehicle ages data, with task force in September of 2008 to make recommendations for appropriate reporting rules.

For questions or more information contact srs@bhlaw.com.