Federal EPA Greenhouse Gas Reporting Rule

Greenhouse Reporting Rule Published in October 2009

The Greenhouse Gas Reporting Rule was published in the Federal Register on October 30, 2009 and took effect on December 29, 2009. The rule requires facilities that emit more than 25,000 metric tons of carbon dioxide equivelents per year to report their emissions to EPA annually.

Manure management is one of the listed categories (subpart JJ of the rule). Facilities that where emissions from manure handling and storage systems exceed 25,000 metric tons carbon dioxide equivelent will need to report under this rule. Emissions from land application and/or agricultural land are not included in this reporting rule. The rule stipulates that faclities below the the following thresholds will not need to report under the rule:

  • 29,300 Beef Cows
  • 3,200 Dairy Cows
  • 34,100 Pigs
  • 723,600 Layers
  • 38,160,000 Broilers
  • 7,710,000 Turkeys

Operations above these thresholds must report if the calculated emissions exceed the 25,000 metric ton threshold.

For more information on the rule see the EPA website.

Archive - MU Comments on the Draft Rule - Spring 2009


EPA released published draft rules for greenhouse gas emission reporting requirements on April 10, 2009 in the Fedral Register. This is the rule making process that gave us the "cow tax" in an preliminary version. The comment period ended June 9, 2009.

The proposed rules did not include requirements for reporting "methane from ruminant animals via enteric fermentation." This means the "cow tax" did not make it into the proposed rules and likely will not be adopted.

The rule proposed rule could affect animal feeding operations in other ways. Any "manure management system" that releases more that 25 metric tons of carbon dioxide equivelants annually will be required to report under these rules. This rule, as proposed, would mostly affect large operations using anaerobic lagoons. We estimated that hog operations with 20,000 head and dairy operations with 1,500 head could be affected.

The information sheets about the rule state that other sources of agricultural greenhouse gas release are not to be regulated. Examples of activities not affected by reporting requirements include in-field burning of agricultural residues, composting (not manure), and cultivation of crops.

University of Missouri Commercial Agriculture Program submitted comments to USEPA.

Other materials available on the proposed rule include: