EPA’s Revised GHG Rule for Electronics and Semiconductor Manufacturers Reply

The United States Environmental Protection Agency (EPA) has issued a pre-published version of their revised Greenhouse Gas reporting rule for electronics and semiconductor manufacturers(40 CFR Part 98 Subpart I). There are many changes in this revision that will reduce the QA/QC requirements of the rule.

The major highlights include modifications to the apportioning model requirement as well as the addition of a stack testing option for reporting emissions. For those facilities that track actual gas consumption, the apportioning model will no longer be required. However, for the facilities that will still need the apportioning model to track their gas usage, the verification standard used to measure actual gas usage from modeled gas usage will be increased from 5 percent to 20 percent. The stack testing option is an alternative method for calculating process gas emissions in place of the standard calculations provided by the subpart.

As the regulation is effective January 2014, RY2013 reporting will not be affected. The regulation will affect 2014 reporting which will be submitted in 2015.

If you have any questions, or require more information or assistance, please contact John Baycroft at 508.970.0033 ext. 144 or jbaycroft@capaccio.com.

GHG Verification Deadline and Important Information Reply

This is a reminder to all Massachusetts Greenhouse Gas (GHG) Reporters that the deadline for verification
of reporting year 2012 emissions is December 31, 2013. If your facility reports GHG emissions to the Massachusetts Department of Environmental Protection (MassDEP) and has not been verified in the past, you will need to complete a verification for reporting year 2012.

In order to help MassDEP facilitate outreach and assistance to facilities subject to this regulatory deadline,
MassDEP is requesting that a representative from your facility send an email to massdepverification@theclimateregistry.org at your earliest convenience and, if possible,
before October 15
to indicate that you are aware of the requirement to complete verification of the 2012 MA GHG Facility Report by December 31. A complete list of verifiers can be found at the MassDEP website, http://www.mass.gov/dep/air/climate/reporting.htm, as well as step by step guidance on how to complete the verification process.

CAPACCIO can assist with getting you ready for verification. Please contact John Baycroft at 508.970.0033 ext. 144 or jbaycroft@capaccio.com for assistance or more information.

Greenhouse Gas and Source Registration Due Dates Approaching Reply

The Environmental Protection Agency (EPA) and Massachusetts Department of Environmental Protection (MassDEP) Greenhouse Gas (GHG) and Source Registration reporting deadlines are fast approaching.

EPA Mandatory Greenhouse Gas Reporting – Due April 1st

The EPA mandatory GHG reporting regulation [40 CFR 98] requires any person owning, operating, or controlling the following facilities to report their 2012 carbon dioxide equivalent (CO2e) emissions to the EPA:

• One of 17 identified industry categories
• One of seven identified industry categories, that emit greater than 25,000 metric tons or more of CO2e per year
• Facilities that do not meet the above, that have combustion units in aggregate equal to or greater than 30 million Btu per hour, that emit 25,000 metric tons or more of CO2e per year from fuel combustion
• Identified suppliers, producers and importers of GHGs

All requested data must be reported using the EPA’s online Electronic Greenhouse Gas Reporting Tool (e-GGRT) by April 1, 2013.

Mass Air Source Registrations and Emissions Statements Annual Filer Reports – Due April 15

MassDEP requires submittal of Air Source Registration/Emission Statements annually for some sources and triennially (every three years) for others. The MassDEP has implemented staggered filing deadlines as follows:

Annual filers
 Operating Permit facilities must file by April 15, 2013
 Non-Operating Permit facilities that are required to file annually must file by May 15, 2013
Triennial filers
 Facilities required to file every three years will receive notification from the MassDEP that their filing is due on either June 3 or July 15, 2013

MassDEP expects filers to use its eDEP on-line source registration filing system. Submittal of hardcopy form is not required.

If your facility meets the criteria under 310 CMR 7.12 for filing Source Registration (SR), reports are due regardless of whether MassDEP sends you a letter. However, you should check the mailing list on the SR web page at Filing Schedules & Deadlines first to see if your facility has been deferred to a later year. If you think there is a mistake in the list, and you should (or should not) be on it (or scheduled for a different year), e-mail air.quality@state.ma.us explaining why the list is wrong.

NOTE: You may be directed by MassDEP to submit a Source Registration through communications other than the annual notice letters. For example, you may be directed to submit as part of an inspection, enforcement action, or permit. You must submit when so directed regardless of whether or not you receive one of the annual Source Registration notice letters.

Mass Mandatory Greenhouse Gas Reporting – Due April 15

The MassDEP mandatory GHG Reporting regulation [310 CMR 7.71] requires any person owning, operating, or controlling the following facilities to report their 2012 carbon dioxide equivalent (CO2e) emissions to the MassDEP:

• All Operating Permit facilities with GHG emissions (310 CMR 7.00, Appendix C)
• All facilities that emit greater than 5,000 short tons of CO2e per year

All required data must be reported to the Climate Registry Information System (CRIS) by April 15, 2013.

Please note: Per an update to the General Reporting Protocol dated January 2nd, 2013, there are updated emission factors that are to be used for reporting this year. See the link below for more information:

http://www.theclimateregistry.org/downloads/2013/01/2013-Climate-Registry-Default-Emissions-Factors.pdf

Reporting facilities that have not previously been verified will also be required to verify their reporting year 2012 emissions by December 31, 2013.

For assistance with your SR or GHG reporting, please contact John Baycroft at 508.970.0033 x144 or jbaycroft@capaccio.com. We can sit alongside and assist you in the process, peer review your submittal, or complete the entire process for you.

Reminder – 2012 CDP Reporting Deadlines are Approaching Reply

The Carbon Disclosure Project (CDP) reporting deadlines for 2012 are rapidly approaching.  As a reminder, below are the upcoming deadlines. The CDP rankings are widely used to evaluate the performance and transparency of publically traded companies (even Google Finance prominently lists CDP rankings as part of company key stats and ratios).   Guidance on CDP reporting and information on the scoring methodology is available on the CDP website.

The timeline for Carbon Reporting for Investor CDP:

  • Feb 1:  CDP sends out its annual information request to companies worldwide
  • May 31:  Deadline for corporations to submit their responses
  • Sept –  Publically disclosed information is published on the CDP website

 The timeline for Carbon Reporting for Supply Chain CDP:

  • April 1:  CDP sends out its annual information request to companies worldwide
  • July 31:  Deadline for suppliers to submit their responses
  • Jan – Publically disclosed information is published on the CDP website

The timeline for CDP Water Reporting:

  • Feb 1 – CDP Water Disclosure Information Request to targeted companies
  • June 30 – Deadline for companies to respond to the questionnaire
  • Oct-Nov – Public response data is published on CDP website

Capaccio Environmental Engineering, Inc. has assisted our clients with sustainability strategic plans, benchmarking, gap analysis, carbon and water footprinting, program implementation, data management, and reporting to help improve rankings as well as address other important sustainability performance objectives.   We are proud of the fact that our clients consistently appear at the top of both environmental and business performance lists, which is consistent with our mission of “helping industry and the environment prosper.”

For additional information or assistance in completing or reviewing reports, please contact us at information@capaccio.com.