Is your organization prepared for Oregon’s new mandatory greenhouse (GHG) gas reporting rules?
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 data for the 2021 calendar year to be submitted beginning in the Spring of 2022.
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 2021 annual emissions to be equal to or greater than 25,000 MTCO2e, Cameron-Cole can provide your verification needs.
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.
1. Start with your GHG data.
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 Department of Environmental Quality (DEQ).
Under Oregon’s new 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 2021 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.
2. Select a 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.
3. Build upon your 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. As an accredited verification body under a number of federally recognized programs and standards, Cameron-Cole is poised to assist your company with all of your verification needs, for Oregon DEQ, and beyond.
With deadlines for emissions verification fast approaching, you need to prepare and ensure you avoid costly delays and unanticipated data collection problems.
Cameron-Cole is an OR DEQ-accredited verifier of emissions reporting. Contact us to get started with your verification requirements ahead of your 2022 deadline.
