Greenhouse gas reporting

1. Greenhouse gas reporting Thresholds and Procedures for Reporting Facilities

2. Introduction • As of January 2011, Washington’s reporting threshold for greenhouse gases is 10,000 metric tons of carbon dioxide or equivalent • In other words: GHG ≥ 10,000 mt CO2e • Many companies required to report may never have reported before • If companies right at the reporting threshold reduce their GHGs then they may be relieved of the reporting burden

3. Introduction • What are the applicable laws and governing agencies? • How do we find companies or facilities which might be at or just above the reporting threshold? • What is their reporting burden? • Where can they find technical assistance for reporting, or, preferably, reducing GHGs?

4. Laws and Authorities • Federal, State, and International authorizing legislation and treaties • Federal, State, and International regulatory and monitoring agencies

5. From UNFCC to Copenhagen COP 1, The Berlin Mandate COP 2, Geneva, Switzerland COP 3, The Kyoto Protocol COP 4, Buenos Aires COP 5, Bonn, Germany COP 6, The Hague, Netherlands COP 7, Marrakech, Morocco COP 8, New Delhi, India COP 9, Milan, Italy COP 10, Buenos Aires, Argentina COP 11, Montreal, Canada COP 12, Nairobi, Kenya COP 13, Bali, Indonesia COP 14, Poznań, Poland COP 15, Copenhagen, Denmark COP 16, Mexico COP 17, South Africa • UNFCCC • International treaty • Annex I, II & developing countries • COPs • COP 15, Copenhagen Accord • International agreement • 183 countries signed • Proposed targets • COP3, Kyoto Protocol • Legally binding agreement • 186 countries ratified • Binding targets 2008-2012

6. Applicability - 40CFR98 (Code of Federal Regulations)Information sourced from ENVIRON International Corporation EPA: Facility Level Reporting for Direct Emissions Company owned and operated sources Purchased finished energy, generated off-site, used by company operations Consequence of company but occurs from/at other sources SCOPE 2 Indirect SCOPE 1 Direct SCOPE 3 Other Indirect EPA: Product Use Reporting for Fuel and Gas Suppliers “Core” Emissions

7. GHG Reporting Requirements • As of November 2008

8. WA State • Washington Bill 6373 passed into law March 19, 2010, builds on 2008 legislation • Sets the threshold for reporting to 10,000 mtCO2e • Sets goal for reduction of GHGs to 1990 levels by the year 2020, further subsequent reductions • Creates system for monitoring and reporting emissions • Mandates reporting once pollutant is determined, subject to enforcement and penalties • Requires 5-year air permits • Requires rule-making: WAC in development (173-441) • Requires consistency with EPA, 40 CFR 98

9. Who Must Report • EPA and Washington Department of Ecology (DOE) requirements differ • Food manufacture not exempt • Biomass included in calculation • Fuel distribution category broader • No inventory of threshold-level emitters exists • Most of industry data are private and therefore not easily available

10. Finding Threshold Facilities • Different ideas about where to start – consumption? production? distribution? • Supply chain studies unwieldy, can double count • Energy use considered confidential, “trade secret” • Can a proxy be found for energy use?

11. Finding Threshold Facilities • Contact with Department of Ecology • Research of Academic Institutions, studies • Nicholas Institute at Duke University study correlating energy use and employee number • Employee numbers are available through public database

12. Compiling Facility List Step 3, Identify impacted facilities Step 2, Identify Impacted industries Step 1, Identify threshold sizes

13. Results

14. Reporting Technical Assistance • After identifying facilities which are at or near the reporting threshold, what kind of outreach needs to be done?

15. General Provisions Mandatory Reporting Rule • Uses 3 tables to categorize industry types that must report GHG emissions • Table 1: Must report regardless of the amount emitted • Table 2: Report all sources of CO2e GHG emissions • Table 3: Report emissions from stationary fuel combustion devices – focus of our model industries

16. Direct Emitter Reporting Report GHGs for all source categories with calculation methodologies. START Source category listed in Table 1? yes no Emit ≥ 25,000 mt CO2e from all source categories? Report GHGs for all source categories with calculation methodologies. Source category listed in Table 2? yes yes no Aggregate maximum rated heat input capacity of <30 mmBtu/hr? no • Threshold Notes: • CO2emissions from combustion of biogenic fuels are not counted • Stationary source combustion threshold excludesportable equipment, emergency generators or equipment, flares, irrigation pumps, certain hazwaste combustion • Emissions transferred offsite areincluded yes No reporting needed no Emit ≥ 25,000 mt CO2e from stationary fuel combustion? Report GHGs for stationary fuel combustion only yes no No reporting needed yes no

17. Reporting • Abbreviated Emissions Report • 2010 only • Full Emissions Report • Facilities identifying information • Emissions breakdown • Verification data • Best Available Monitoring Methods • Description • Missing data procedures

18. Technical Assistance • Industry Groups and Associations • U.S. Department of Energy’s Energy Efficiency and Renewable Energy Program (EERE) • Industrial Assessment Centers • EPA and DOE industry-specific guidance

19. Key Steps • Contact all industries now, prioritized by size • Keep communication simple • Advise of information to gather in anticipation of reporting • Provide links to technical assistance

20. Final Thoughts • This is a moving target • WA reporting rule is yet to be developed • Federal legislation (Kerry –Lieberman bill) may change all • There’s almost too much information available • Greatest need for TA is distilling information • Idea for reporting needs to be “sold” • Cost-Benefit of GHG reduction as correlated with efficiency needs to be made clear • Emphasize information-gathering stage, nothing punitive