Maintaining Greenhouse Gas Inventory Compliance at Hill Air Force Base in the Midst of Regulatory Uncertainty

摘要

Following the establishment of reference baseline greenhouse gas (GHG) inventories for the Hill Air Force Base (AFB) Main Base and the Utah Test and Training Range, significant preparation is underway to ensure compliance among the new rules associated with GHGs. Having been established over the relatively short course of a few years, there is a significant amount of GHG-related regulatory requirements. Rules concerning Hill AFB include the Mandatory Reporting Rule, the Prevention of Significant Deterioration and Title V GHG Tailoring Rule, and Executive Order 13514. Preparation for the requirements set forth within these rules has been extensive. Data collection efforts and overcoming the learning curve associated with new calculation methodologies are on-going tasks. Significant updates to the Hill AFB air emission database have been made to accommodate new source categories and data requirements. Meanwhile, key differentiators between standard emissions reporting and GHG reporting pose logistical problems. Differences such as data reporting of fiscal year versus calendar year, metric tons versus short tons, and the incorporation of global warming potentials all require additional steps beyond the standard emissions reporting process. As deadlines for the submission of rule-specific data approach, the mechanisms needed for submittal, as indicated by the rules themselves, remain elusive. Given the likely short response time, organization will be essential. Detailed records of GHG processes, material consumption, locations, and calculation methodologies will need to be maintained to the highest standard.