Oregon's GHG reporting rules now require full third-party verification for many facilities and suppliers.
The Environmental Quality Commission (EQC) approved Oregon's original GHG reporting rules in 2008, which established GHG registering, reporting, and other requirements for facilities that emit GHGs, including fuel and electricity suppliers. These rules were updated in 2020, making these requirements mandatory for Oregon facilities and requiring third-party verification.
This verification rule is applicable to relevant Scope 1 sources that hold an Air Contaminant Discharge Permit (ACDP) or Title V operating permit in Oregon if the source emits equal to or greater than 25,000 metric tons of carbon dioxide equivalent (MTCO2e) during the calendar year; as well as fuel importers, natural gas suppliers, electricity suppliers, and large landfills. If you’re required to report GHG emissions, and you expect your annual emissions to be equal to or greater than 25,000 MTCO2e, verification is required.
To help you navigate this new verification process efficiently so that you can continue focusing on your core business operations, we’ve put together some information to help get you started.
Your Emissions Data: The Foundation of Oregon GHG Verification
Data is the key to your GHG verification process. Your emissions data must be collected and aggregated into quantifiable numbers that can be reported to the Oregon Department of Environmental Quality (DEQ).
Under Oregon’s mandatory GHG verification requirements, the DEQ primarily targets large facilities and suppliers that emit anthropogenic emissions equal to, or greater than 25,000 metric tons of carbon dioxide (MTC02e) within the calendar year and each year moving forward. Total carbon dioxide equivalent emissions (CO2e) must be calculated as the sum of the CO2, CH4, N2O, and each fluorinated GHG that is required to be reported. Note that there are some exclusions: CO2 from biomass-derived fuels; some emissions associated with Bonneville Power Administration purchases; municipal solid waste landfills; and Natural Gas supplier reports for interstate pipelines are all exempted from your organization’s emissions threshold. Fuel suppliers or in-state producers that share common ownership must aggregate reports together to determine whether they meet the threshold for verification.
With deadlines right around the corner, it is imperative that you start as quickly as possible to document your emissions reports from last year. Note important annual deadlines for your market here:
| Market | Deadline |
| Petroleum and natural gas systems | March 31 |
| Air quality permit holders | March 31 |
| Natural gas suppliers | March 31 |
| Fuel suppliers and producers | April 30 |
| Electricity suppliers | June 1 |
Remember that your GHG data must be in conformance with record keeping and metering accuracy requirements, so it is critical that your organization prepare for your deadlines with reportable numbers, as well as a firm grasp of the data systems behind those reported values.
How to Select an Oregon DEQ-approved Verifier
Quantifying your emissions can be a daunting task. Understanding the importance of accurate data and the need for standardized evaluation and comparison, Oregon now requires a DEQ-approved verifier to perform emissions verification services. Verifiers for the GHG Reporting Program must first be accredited by the California Air Resources Board (CARB) or be a part of the American National Standards Institute’s National Accreditation Board (ANAB) GHG Validation and Verification Body program. Once validated, the verifying body must pass exams for Oregon qualification. In December 2021, Cameron-Cole was among the first group of companies to become an approved verification body for the OR DEQ’s Greenhouse Gas Reporting Program. As such, Cameron-Cole is accredited to provide verification services for all emissions sources for all industrial sectors under Oregon’s program, including stationary combustion sources, electricity suppliers, natural gas suppliers, natural gas systems, and facility process emissions.
Site Visits in Oregon’s Full GHG Verification Process: Plan Early, Prepare Thoroughly
Oregon DEQ GHG verification requirements include a full verification for all entities subject to verification, which means that site visits are required as part of the verification process. A full verification involves review of the entire emissions data report and supporting documentation, along with an on-site evaluation of emissions sources, monitoring systems, and recordkeeping practices.
ompared to prior years, when limited verification approaches may have applied, a full verification requires additional coordination and preparation. Verifiers must assess how emissions data is generated, tracked, and reported within the facility’s systems, and confirm that reported values are supported by underlying records and processes. As a result, site visits play an important role in ensuring the completeness and accuracy of reported GHG data.
Because site visits require scheduling and participation from facility staff, it is important to begin planning early. Verifier availability is often limited during peak verification season, and delaying engagement can lead to compressed timelines or challenges meeting submission deadlines.
To prepare for a successful site visit, organizations should ensure that emissions calculations are finalized, supporting documentation is organized and accessible, and staff responsible for data collection and reporting are available to answer questions. Reviewing any changes to equipment, processes, or calculation methodologies since the prior reporting year can also help streamline the verification process and reduce follow-up requests.
With verification deadlines approaching, early preparation for a full verification year can help minimize disruptions, avoid last-minute data gaps, and support timely submission of verification materials to the Oregon DEQ.
Building Upon Your GHG Emissions Data
Although this process is state-mandated, emissions reporting has added benefits. Once your data has been collected and documented, you can create emissions baselines for your organization, which can help you quantify energy expenditure and pinpoint areas where your energy consumption can be optimized to reduce emissions and save costs. Understanding your emissions reports also empowers you to identify operational processes that may contribute to excessive emissions and improve upon them to reduce your total carbon footprint to meet internal and stakeholder goals.
Utilizing an accredited third-party verifier also sets the stage for your organization to begin participating in climate-related disclosures such as the Carbon Disclosure Project (CDP) or the Task Force on Climate-Related Financial Disclosures. Participating in these voluntary reporting programs leads to increased shareholder support, reduced climate-related organizational risk, and improved overall sustainability toward a carbon-free future.
With deadlines for emissions verification fast approaching, you need to prepare and ensure you avoid costly delays and unanticipated data collection problems.
