President's Letter - Nov. 2009

Date:               25 November, 2009
From:              James Mayer, President, BOMA Wichita Chapter
To:                  BOMA Wichita Chapter Members
Subject:          EPA’s Greenhouse Gas Reporting Rule

Good day members!  I hope this letter finds you all well and having a great day!

Recently the Environmental Protection Agency (EPA) Administrator signed the final rule requiring mandatory reporting of greenhouse gas (GHG) emissions from certain sources in the commercial and industrial sectors.  This rule covers and requires the reporting of emissions of CO², methane and nitrous-oxides generated from the combustion of natural gas and other fuels such as methane.  While the rule does require reporting of emissions over a certain amount, it does not require retrofits or replacements for older equipment, nor does it establish penalties for inordinately high emissions, only that the emissions be reported.  For those that fall into the requirements of the rule, it does require monitoring to begin on January 1, 2010 with the actual first reports are not due until the end of March.

With the rule being over 700 pages of wadingly boring reading, it is difficult to ascertain the actual requirements, especially if you are an owner or manager of a large facility containing multiple boilers.  I, for one, was having a very difficult time trying to decipher the language of the rule to see if I had new reporting requirements that had to be met.  I was lucky enough to have access to other specialists from the City’s Environmental Services that were working on that very topic and believe we have found a concise, easy to understand ‘white paper’ (attached) that should help in understanding if the rule impacts your facilities or not.

One section of the rule speaks directly to the topic of commercial boilers and makes them cumulative on a per location basis, and luckily not on a portfolio basis.  In a nutshell, if you have a facility with single or multiple boilers, reporting requirements do not apply to you unless your site aggregate total is ≥30MMBtu’s of heat input capacity.  Hopefully none of you will be required to begin the laborious task of emissions monitoring and submitting these reports.  Beyond commercial boilers, much of the rule only applies to coal and gas burning power generating facilities, solid waste landfills, and industrial glass, metal and pulp manufacturing facilities.

Here is the attached ‘white paper’, and I would like to wish you all a Happy Thanksgiving!

Best Regards,

Jim Mayer, City of Wichita

President, BOMA Wichita