Clearing the Air on New GHG Standards
by Alex Chamberlain
Erin Manitou-Alvarez, M.S.
January 4, 2012
Implemented in 2009, EPA’s Greenhouse Gas Reporting Program (GHGRP) has led many businesses to ask more questions. Such as, who needs to report? What is reported? When does the reporting need to be completed?
A range of industries are affected by the GHG regulations, including fossil fuel suppliers, landfills, pulp and paper, vehicle manufacturers, electricity generation and petroleum refineries. Facilities from affected industries emitting CO2, methane, N2O, sulfur hexafluoride, hydrofluorocarbons or perfluorocarbons are required to assess their emissions sources and the total quantity released.
Reporting requirements are triggered if a facility’s annual emissions exceed 25,000 metric tons of CO2 equivalents (CO2e). Any facility using an All-in category source must complete a GHG report regardless of how much GHG is emitted. In addition, any site that uses stationary combustion units with an aggregated maximum rated heat input capacity that is equal to or greater than 30 mmBTU/hour is required to complete the report. The reporting period lasts from January 1 to December 31, with a reporting deadline of March 31. Facilities that submit reports with any calculation errors will be allowed 45 days to submit a corrected report.
Those required to submit a GHGRP report will need to determine their facility’s total annual GHG emissions from each source category, excluding CO2 generated from biomass or biofuels. Facilities that do not meet the reporting threshold can choose to submit a voluntary report. Two new GHG standards – the Corporate Standard and the Product Life Cycle Standard – have been designed to assist facilities to voluntarily submit GHGRP reports.
Under the Product Life Cycle Standard, businesses account for their emissions at each juncture of their product’s pre-processing, manufacture, storage, distribution, use and end-of-life stage. Businesses would identify hot spots in the product life cycle and concentrate their efforts to reduce GHG emissions in those spots.
As with mandatory GHG reporting, it is necessary to report the emission factors and Global Warming Potentials (GWPs) used.
The Corporate Standard reports all GHG emissions related to a facility’s scope-3 emissions – GHGs that are released as a result of business operations, but do not occur at the facility. Emissions reports include activities such as the shipment of products with a third party hauler.
When reporting corporate emissions, follow the principals of relevance, completeness, consistency, accuracy and transparency. Report all GHG emissions from each scope-3 activity, or have justification for any exclusion. As in mandatory GHG reporting, include GHG emissions from scope 1 and 2 activities, which are directly related to business and occur on site. Establish a base year for scope-3 reporting, and prepare descriptions of all such activities, including calculation methodologies, related emission factors and GWPs. Emission reduction targets can be selected and methods developed for measuring the goal.
Some companies have utilized EMS software solutions that electronically store the necessary records and generate reports.
For now, the reporting of GHGs based using the Corporate Standard or Product Life Cycle Standard is optional. However, such reporting may become a mandatory part of national GHG reporting in the future.
Many large-scale businesses are adopting voluntary GHG reporting as part of their sustainability initiatives, and are already prepared in case these new standards become mandatory. GHG reports are now part of corporate sustainability efforts. A free guide for proper emissions reporting is available at http://bit.ly/vnw0QD. PE
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