By Alyssa Moir, Marten Law Group PLLC
“Large stationary sources and transportation fuel suppliers in the State of Washington would have to report their 2012 greenhouse gas (GHG) emissions beginning in 2013 under rules recently proposed by Washington's Department of Ecology (Ecology),” writes Alyssa Moir. “Earlier Ecology proposals would have required reporting of 2009 GHG emissions before the end of 2010, but Ecology has revised its approach over the time this rule has been under development to be more consistent with federal GHG reporting requirements. However, Ecology's latest proposal still will apply to more facilities and fuel suppliers than the federal rules. Ecology accepted comments on the proposed rule through October 14, 2010, and conducted two public hearings on October 6 in Spokane and October 7 in Lacey.”
“Washington has by statute adopted a Climate Change Framework that sets (GHG) reduction targets over the next several decades. As part of this effort, Ecology has been directed to develop and implement a reporting system to establish a baseline inventory of GHGs emitted in the state,” explains the author. “For similar reasons on the federal level, EPA has created a mandatory GHG reporting rule. Washington adopted its GHG reporting statute and Ecology began developing a GHG reporting rule before EPA's reporting rules were available even in draft form. After the federal rules were released, the Washington legislature passed SSB 6373 in early 2010, revising the state GHG reporting statute to be more in line with EPA's reporting requirements. Ecology then worked with a stakeholder group to develop GHG reporting rules that would implement the revised state GHG reporting statute.”
Moir then outlines the proposed rule, specifies the fuel types that are impacted, and discusses what other states are doing with greenhouse gas emissions.
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Alyssa Moir of the Marten Law Group practices environmental and land use litigation with a focus on renewable energy, climate change issues, hazardous waste cleanup, and permitting in the Pacific Northwest. Alyssa earned her Juris Doctor from the University of Washington School of Law where she served on the Editorial Board of the Pacific Rim Law & Policy Journal and provided pro bono services through the Environmental Law Clinic. Prior to joining the Marten Law Group, Alyssa was a law clerk to the Honorable Marlin J. Appelwick, Washington State Court of Appeals, Division 1.