Washington State Climate Commitment Act Greenhouse Gas Reporting and Verification

It's important to note that before this legislation was enacted, about 75 percent of the GHG emissions now covered under the Act were either unreported or reported using methods that did not meet the new law's standards. To support the implementation of the cap-and-invest program and ensure accurate emissions reporting, the Department of Ecology updated Chapter 173-441 WAC, titled 'Reporting of Emissions of Greenhouse Gases.' These revisions became effective on March 12, 2022. The Greenhouse Gas Reporting framework under the Washington State Climate Commitment Act closely resembles the California Air Resources Board (CARB) Mandatory Greenhouse Gas Reporting Regulation (MRR).

Mandatory GHG Reporting:

The updated 173-441 WAC establishes Washington State's mandatory greenhouse gas (GHG) reporting requirements. Reporters who are required to report their GHG emissions to Ecology include: 

• Facilities that emit at least 10,000 metric tons CO2e per year,
• Suppliers of natural gas or other fuels that provide products within Washington in quantities that when combusted or oxidized completely, emit greenhouse gases equivalent to at least 10,000 metric tons CO2e per year, or
• Electric power entities that deliver electricity within Washington whose production resulted in at least 10,000 metric tons CO2e per year.

Reporting requirements will cease if:

• Reported emissions are less than 10,000 MT CO2e for 5 consecutive years, or 
• Reported emissions are less than 5,000 MT CO2e for 3 consecutive years, or 
• Operations cease.

Greenhouse Gases to be reported:

• CO2 including Biogenic CO2  
• CH4
• N2O
• Fugitive releases of GHG emissions from biomass 
• Hydrofluorocarbons and Perfluorocarbons 
• Sulfur hexafluoride 
• For electronics manufacturing: fluorinated heat transfer fluid

There are no de minimis emissions categories. 

Reporting Tools to be used:

Facilities are mandated to calculate their applicable emissions annually, using the calendar year as a basis. The calculation methodologies should align with those specified in the U.S. EPA’s 40 C.F.R. Part 98. These emissions are to be reported either via the EPA’s e-GGRT XML report or the e-GGRT IVT XML report, as applicable. In certain cases, Ecology’s Facility Excel Reporting Tool may be used instead. Specifically, natural gas suppliers, other fuel suppliers, and electric power entities are required to utilize GHG reporting tools provided by Ecology for their submissions. Additionally, all facilities must report product data using Ecology’s Facility Reporting Tool.

GHG Verification:

Mandatory reporters emitting a minimum of 25,000 metric tons of CO2 equivalent (CO2e) annually, as well as both voluntary and mandatory participants in Washington’s Cap-and-Invest Program, are obligated to have their emissions and product data independently verified. This verification must be conducted annually by an accredited third-party, with this requirement commencing from the 2023 calendar year onwards.

Full verification vs less intensive verification:

Reporters subject to third-party verification are required to undergo full verification at least once every three years. The initial year of this cycle must involve full verification. For the subsequent two years within this three-year period, a less intensive form of verification is permissible under the following conditions:

1. The reporter does not receive an adverse verification statement in any year within the three-year period.
2. The third-party verifier is able to provide findings with a reasonable level of assurance.
3. There is no change in the third-party verifier during the period.
4. The operational control of the reporter remains unchanged.
5. There are no significant changes in the sources or emissions of the reporter. Notably, a variation in emissions greater than 25 percent compared to the previous year's emissions is deemed significant.

Less intensive verification involves no site visits and requires fewer detailed data checks and document reviews of the annual GHG report. This approach is based on the analysis and risk assessment found in the most recent sampling plan developed as part of the last full verification.

Reporting and Verification Deadlines:

*EPE (Electric Power Entities) GHG emissions reports are due on June 1

In addition to the specific requirements already mentioned, there are also general requirements that entities must adhere to. These include aspects related to monitoring, reporting, recordkeeping, as well as standards for calibration and accuracy. Furthermore, provisions for handling missing data and other related operational details are also encompassed within these requirements.

Through this program, Washington aims to cap and reduce greenhouse gas (GHG) emissions from its largest sources and enable the state to meet its GHG emission limits and transition towards a future low-carbon economy.

Cameron-Cole is a Washington Department of Ecology-accredited verification body with over 500 GHG verifications and more than 40 years of GHG verification experience. Contact us for more information on your reporting requirements. Follow us on LinkedIn to keep up with the latest Cameron-Cole updates and to find out more about how we transform risk into positive impact and value.