Sometimes No News IS Bad News:
Not all AB32 GHG Mandatory Reporters Have Been
Notified
Do you
think you're off the hook for reporting GHG emissions because you
haven't received an official letter from the California Air
Resources Board. Don't throw a party just yet....not everyone who
should be notified has been notified.
If you are concerned that your firm may be over the CARB mandatory
reporting threshold of 25,000 metric tonnes CO2 equivalent, or fall
into one of the mandatory reporting categories, but haven't received
formal notification by the agency, there are three steps to take
that will keep your company on the right side of CARB on this issue
and ensure you aren't on another hook being paraded around as an
example:
- As
a manufacturer, your facility may exceed one or more of three
separate thresholds that trigger mandatory reporting to CARB:
a)
General Combustion Sources: CARB's mandatory reporting
threshold on a per facility basis is 25,000 metric tonnes (MT) per
year CO2 emissions from combustion sources under your operational
control.
b)
On-Site Power Generation (power): If your on-site power
generation facility generates 1MW and/or 2,500 MT CO2 emissions.
c)
On-Site Cogeneration (combined heat and power): If your
on-site power generation facility generates 1MW and/or generates
2,500 MT CO2 emissions
If you think you have a facility
that exceed one or more of the reporting threshold, then you need to
confirm that by doing a quick evaluation of CO2 emissions.
- If
the answer is yes, then you are required to report your emissions
for any facility that exceeds any of the above reporting
thresholds between April 1 and June 1, 2009 -
regardless of
whether you have been officially notified or not.
a)
General Combustion Sources: You will need to report:
I.
GHG emissions by gas type (i.e., CO2, N2O, CH4) for the
entire facility
II.
GHG emissions produced for each fuel type used
III.
Fuel consumption, by fuel type for the entire facility
IV.
Fuel consumption for individual process units or groups of
units where separately metered
V.
Indirect energy usage (purchased KWh).
b)
Cogeneration Units:
I.
GHG emissions by gas type (i.e., CO2, N2O, CH4) for the
entire facility; specific regulations for specific types of
combustion such as acid gas scrubbers
II.
Fuel consumption, by fuel type for the entire facility
III.
Average higher heating values by fuel type, if measured
IV.
Average carbon content by fuel type, if measured
V.
Indirect energy usage (purchased KWh).
c)
Electricity Generation Units:
I.
GHG emissions by gas type (i.e., CO2, N2O, CH4, SF6 and HFC)
for the entire facility; specific regulations for specific types of
combustion such as acid gas scrubbers
II.
Fuel consumption, by fuel type for the entire facility
III.
Process emissions from acid gas scrubbers/acid gas reagent
IV.
Fugitive emissions at facility level by facility type (i.e.
CH4, HFC, CO2)
V.
Average high heating values by fuel type
VI.
Average carbon content by fuel type
VII.
Steam
VIII.
Boiler efficiency
IX.
Indirect energy usage (purchased KWh).
CARB's
regulatory requirements for reporting are much more detailed than
what is outlined above and MCCV can connect you with experts to
assist you.
-
Once you've completed your GHG inventory it is worthwhile to
pursue a second party evaluation of your inventory prior to
formally reporting to CARB. That way you avoid any surprises and
have an opportunity to assess implications of your inventory to
your future business operations.
Once you've submitted your 2008 GHG inventory report to CARB , you
will be required next year in 2010 to have your 2009 report
"verified" by a third-party verifier. Although reporting
requirements do begin in 2009, CARB recognizes that some
facilities do not have the requisite monitoring and record-keeping
equipment in place to record 2008 emissions data. Therefore, the
regulations provide for a one-year transition period where GHG
emissions may be calculated based on "best available data and
methods."
Additionally, although third-party verification is required for
subsequent reporting years, CARB has made it optional for 2009
Reports. Electricity generating and cogeneration facilities must
submit their Emissions Data Reports by April 1, 2009, while
electricity retail providers and marketers have until June 1, 2009
to report.
MCCV thanks Allan Bedwell of Cantor CO2e for preparing this
information.
