Law360, New York (October 04, 2010) -- Major emitters of greenhouse gases subject to the U.S. Environmental Protection Agency's GHG Reporting Rule are required to monitor and record their GHG emissions on a facility-by-facility basis as of Jan. 1, 2010.

For companies subject to the reporting rule, it is now past the halfway point to the March 31, 2011, deadline for the first annual GHG emissions report. At this juncture, covered facilities should take stock of their efforts to comply with their GHG reporting obligations and to prepare their first annual GHG report.

In doing so, facilities should focus on assessing: a) whether there are any gaps in their reporting scheme; b) if so, how to close those gaps between now and Dec. 31, 2010; c) whether they are on track to meet the stepped-up reporting requirements beginning Jan. 2, 2011; and d) the potential consequences if their annual GHG report is deficient.