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Q23. Are there some sectors where all facilities have to report regardless of whether they meet the 25,000 metric tons CO2e threshold?

A23. Yes.  For some of the source categories, all of the facilities that have that particular source category within their boundaries will be subject to the rule.  For these facilities, EPA’s analysis indicated that all or nearly all facilities with that source category emit more than 25,000 mtCO2e per year, and that an “all in” would simplify their applicability determination.  These source categories include large manufacturing operations such as petroleum refineries and cement production.  For more information on which source categories will be covered, please review the rule and view the General Provisions Information Sheet on the Information Sheet page.


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Source: Legacy FAQ, revised by D. Richards,

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