On March 10, 2009, the U.S. Environmental Protection Agency (“EPA” or “Agency”) published a prepublication Notice of Proposed Rulemaking (“NPRM”) which, if implemented as proposed, would require annual reporting of greenhouse gas (“GHG”) emissions from a broad range of facilities, impacting (according to EPA estimates) more than 13,000 facilities nationwide, including any facility that emits 25,000 metric tons or more of CO2equivalent (“CO2e”) per year in combined emissions.