GHG Reporting/ Verification - Lessons Learned. August 20, 2013

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1 GHG Reporting/ Verification - Lessons Learned August 20, 2013

2 Overview Mandatory Greenhouse Gas Reporting Rules and Methodologies Applicability Thresholds and Dates MassDEP Reporting MassDEP Verification EPA Reporting CDP Reporting Lessons Learned and Strategies

3 Mandatory Greenhouse Gas Reporting Rules and Methodologies MassDEP per 310 CMR 7.71 Uses The Climate Registry s (TCR) General Reporting Protocol and General Verification Protocol EPA per 40 CFR 98 Reporting methodologies included in Subparts A - UU of regulation

4 Carbon Dioxide Equivalent Carbon Dioxide Equivalent (CO2e) Relates the impact of one GHG to an equivalent amount of CO2 emissions Derived by multiplying GHG emission by its GWP Global Warming Potential (GWP) A ratio of the heat trapping ability of a GHG relative to carbon dioxide

5 Global Warming Potential (GWP) GHG GWP CO2 1 CH4 21 N SF6 23,900 HFCs 12 to 11,700 PFCs 6,500 to 9,200 Source: Climate Registry s General Reporting Protocol, dated May Appendix B, Table B.1

6 Applicability Thresholds and Dates MassDEP Operating Permit (OP) facilities with stationary emissions sources that emit GHG Non - OP 5,000 short tons of CO2e emissions Deadline: April 15th After you exceed the threshold once, you must continue to report until you reduce your emissions below thresholds Once below thresholds, must apply for exemption

7 Applicability Thresholds and Dates US EPA 25,000 metric tons of CO2e Deadline: March 31st* After you exceed the threshold once, you must continue to report until you are < 25,000 mt of CO2e for 5 consecutive years < 15,000 mt of CO2e for 3 consecutive years Cease all applicable operations *April 1st, 2013 since March 31st is a Sunday

8 5,000 ton CO2e Equivalents Combust approximately 83,000,000 cubic feet of natural gas Combust approximately 450,000 gallons of No. 2 fuel oil (FO) Combusts approximately 380,000 gallons of No. 5 or 6 FO Uses approximately 500 lbs of SF6 (unabated)

9 MassDEP Reporting TCR General Reporting Protocol v2.0 Stationary Combustion(i.e. boilers, emergency generators, RTO) Mobile Combustion (i.e. cars, trucks, forklifts) Fugitive Emissions (i.e. chillers, water coolers, refrigerators, vehicle A/C, heat transfer fluids) Process Emissions (i.e. CO2, CH4, N20, HFCs, PFCs, SF6) Uses Climate Registry Information System (CRIS)

10 MassDEP Verification TCR General Verification Protocol v CMR 7.71 requires triennial verification of GHG emissions by a third-party Verifier seeks material findings +/- 5% of total CO 2 e emissions

11 Verification Schedule If a facility reported Reporting Year First Verification Due By 2009 CO2 emissions > 25,000 tons 2010 CO2e emissions < 25,000 tons > 10,000 tons 2012 GHG emissions (no threshold) GHG emissions for a year after 2012 (no threshold) /31/ /31/ /31/ and beyond By 12/31 of the calendar year following the year reported

12 Verification Process Select a Verifier on CRIS Data Request Verification Plan Findings Log Verification Meeting Update CRIS Report Verifier Uploads Verification Statement Verification Report

13 Verification Preparation Trace all data to primary source Invoices, generator logs Document information trail GHG Monitoring Plan Narrative Confirm Emission Factors and Methodology Identify all Simplified Emission Methods (SEMs) Ensure they are under the 1,000 mt limit

14 EPA Reporting Subpart A: General Provision Subpart C: Stationary Combustion Subpart D-UU: Source Category Emissions Subpart I Semiconductors NF3 Reportable to EPA (Not MassDEP) Uses Electronic Greenhouse Gas Reporting Tool (e-ggrt)

15 EPA Correspondence Process Receive notification 45 days to respond Can request an additional 30 days Respond to each question Update report as needed EPA only looks at the most up-to-date report

16 CDP Verification Not mandatory Improve score 9%-13% of disclosure score 15%-17% of performance score Scope 1 and 2 emissions must be verified in order to qualify for entry to the Carbon Performance Leadership Index (CPLI) Several verification standards accepted including TCR General Verification Protocol

17 CDP Verification Documentation must Address relevant scope Clearly state verification standard used Clearly state level of assurance Limited (negative format) Reasonable (positive format) Cover current reporting year

18 Internal Verification Team Preparer of GHG Report Facilities Responsible for generators, boilers, refrigerants Purchasing department or gas provider Responsible for purchasing process gas or tracking gas usage

19 External Lead verifier Verification team Verification Team Outside consultant who assisted in preparing report Vendors

20 Verification Example TCR GRP Used for Sample Calculation 100 Million Cubic Feet of Natural Gas Usage Reporter Using 1000 Btu/CuFt Heat Content Emissions (mt CO2e) = 5,320 Boiler 3% Understatement Emissions (mt CO2e) = 5,469 Verifier Using 1028 Btu/CuFt Heat Content

21 Verification Report Section 1 Overview Section 2 Copy of Verification Plan Section 3 Identify Emission Sources The Climate Registry General Verification Protocol Appendix B2 Standard Verification Report Template

22 Verification Report Section 4 Verification Activities Log and Evaluation of Compliance Section 5 Findings The Climate Registry General Verification Protocol Appendix B2 Standard Verification Report Template

23 Lessons Learned Emissions from VOCs combusted in Thermal Oxidation Requires amounts and types of VOCs that are sent to Thermal Oxidizers annually Stoichiometric Simplified Emission Methods (SEMs) Identify SEMs in CRIS 1,000 mt CO 2 e limit for SEMs at a facility per MassDEP 310 CMR 7.71

24 Propane forklifts Lessons Learned Considered mobile combustion for MassDEP report Often overlooked Corporate Emission vs Site Specific Emissions Corporate CDP emissions are not subject to EPA/MassDEP limitations Abatement percentages Apportioning model Purchased vs used

25 Document everything Lessons Learned Verifiers will re-calculate your emissions based on primary data sources to determine accuracy Vendor invoices or purchasing records Runtime logs Service records If data sources change, update your GHG Monitoring Plan

26 Strategies for Improved Reporting Maintain up-to-date GHG Monitoring Plan Document that identifies Sources of all data for GHG emissions Responsible personnel for recordkeeping Ensure complete emissions inventory i.e. all GHG emissions are accounted for Document everything

27 Questions For further assistance, please contact: John Baycroft x144 For further updates and information, visit our Capaccio website: or follow us on