Redefining 'Facility' In GHG Reporting

Law360, New York (January 3, 2011, 3:45 PM EST) -- The U.S. Environmental Protection Agency has expanded the traditional reach of the Clean Air Act by adopting new definitions of the “facility” that is subject to its mandatory greenhouse gas reporting rule for the petroleum and natural gas industry.

Industry and state environmental agencies have grown accustomed to the Clean Air Act’s traditional source-based approach through which the unit subject to applicability determinations and requirements is the group of emission sources located in a contiguous area under common control of the same person or persons. This...
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