Third-Party Verification Of Greenhouse Gas Emissions Reports No Longer Required By The MassDEP Reply

On August 26, 2015, the MassDEP issued an e-mail to Massachusetts Greenhouse Gas (GHG) emissions reporting facilities that it will no longer require verification of GHG reports by an approved verification body once every three years as stated in 310 CMR 7.71(7).  This decision applies to reports for reporting year 2014 and future years thereafter.  Verification of emission reports for years prior to 2014 must still be completed and submitted to MassDEP.

The reason for the change is that MassDEP believes the third party verification program has been successful in improving the quality of reported GHG emissions data to-date.  Each reporting facility in the state has completed verification for at least one emission year.  MassDEP believes the reviews have resulted in significant changes to many reports and that going forward, facilities will continue to implement these changes in future years as part of their own internal verification processes.

MassDEP intends to publish a draft report on the verification requirement in the near future which will include supporting data that was considered in deciding to no longer require the third-party verification.   MassDEP  will likely be proposing amendments to 310 CMR 7.71(7) to replace the current verification requirement with other verification options such as self-certification of reported emissions.

Despite the removal of the third party verification requirement, the accuracy and consistency of data should remain a priority that needs to be addressed by alternate means such as a periodic peer review or GHG emissions audit.

CAPACCIO works closely with companies in assisting with the tracking of GHG emissions and in the preparation and submission of GHG reports to both the MassDEP and the Federal EPA.  CAPACCIO will continue to provide GHG program audits and peer reviews of GHG tracking systems, programs, and reporting.

CAPACCIO will continue to follow any developments from the MassDEP and our air quality experts can help with all your compliance needs.  If you have questions or require assistance, please contact Bob King at 508-970-0033 ext. 113 or or John Baycroft at 508-970-0033 ext. 144 or

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

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 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,, 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 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 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:

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 We can sit alongside and assist you in the process, peer review your submittal, or complete the entire process for you.