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.

Carbon Disclosure Project vs. Taxes – Can you see the similarities? Reply

Spring is in the air, but that also means we are in the midst of tax season and the Carbon Disclosure Project (CDP) carbon reporting season.  At a first glance, you wouldn’t think so, but both filing processes are remarkably similar.  

Filing taxes increases transparency to shareholders, clients, and the public on company financials. Measuring and disclosing greenhouse gas emissions data by participating in the CDP does the same thing on an environmental front.  Both processes can help businesses identify risks, plan for the future, increase efficiency and reduce unnecessary costs.

Other similarities? The CDP offers a detailed Guidance document with step-by-step instructions and explains the reporting system structure in excruciating detail; a striking similarity to tax preparation guidance documents!   The CDP provides a dizzying list of descriptions, codes, and policies. Sound familiar?

As the final step to preparation, the CDP provides a Response Check, or “high level checking service” that reviews responses prior to submission. External consultants review the responses for completeness and offer expert feedback for a standard $1,000 fee. In the tax world, you have your local CPA.

 Keep the deadlines in mind, and do your spring cleaning of paperwork!

MassDEP Greenhouse Gas Reporting: Verification Reply

The Massachusetts Department of Environmental Protection (MassDEP) has posted information on its website related to verification of submitted greenhouse gas (GHG) reports.  Facilities that are required to submit GHG reports to the MassDEP GHG Registry, a subset of the Climate Registry’s Information System (CRIS), must verify their submitted reports once every three years.

The first GHG reports were filed in June of 2010 for reporting of calendar year (CY) 2009 emissions, and were only required of facilities that had carbon dioxide (CO2) emissions from combustion of fossil fuels equal to or greater than 5,000 tons.  The second reports filed this last April, required reporting of all GHG emissions from facilities with carbon dioxide equivalent (CO2e) emissions equal to or greater than 5,000 tons.

To implement the verification process, the MassDEP has set up a staggered verification schedule based on the first year a facility reported and the level of GHG emissions reported.  The flowchart below summarizes the schedule by which verification reports must be submitted to the MassDEP:

Click the image above for a full view of the flowchart.

Facilities are required to hire a third party verifier that is approved by the MassDEP.  A listing of approved verifiers can be found on the MassDEP website at the following link:

http://www.mass.gov/dep/air/climate/verifiers.htm

The MassDEP has created a checklist for facilities to use which describes the steps to be completed for conducting and filing the verification report.  Below is a link to the checklist.

http://www.mass.gov/dep/air/climate/reporting.htm

To assist facilities on how to complete their verifications, the MassDEP will be conducting a verification training webinar on Tuesday, September 13, 2011.  You can sign up to attend the webinar at:

https://www2.gotomeeting.com/register/891659067

If you have any questions about whether your facility is required to report GHG emissions, need assistance with compiling or reporting your data, or have questions on the verification process, please contact Lynn Sheridan at 508.970.0033 ext. 122 or lsheridan@capaccio.com.