It is increasingly common for organizations to report their greenhouse (GHG) emissions, and often times reporting is necessitated by mandatory regulations set in place by local municipalities. The state of Oregon is one example in which mandatory GHG disclosure is required for certain companies and industries.
Examples of Mandatory GHG Reporting Program
EPA Greenhouse Gas Reporting Program (GHGRP)
Originally mandated in 2009, the GHGRP requires select organizations to report their GHG emissions. The reporting requirements apply to large GHG emission sources, fuel and industrial gas suppliers, and CO2 injection sites that in general emit 25,000 metric tons of carbon dioxide equivalent emissions per year in the United States. Approximately 8,000 facilities are required to report their emissions annually. The Environmental Protection Agency (EPA) verifies the reported data and does not require third party verification. Emissions data collected from the reporting program is utilized by the EPA to evaluate trends over time and within specific industries to serve as a guiding principle for the creation of related policies and programs.
California Mandatory Reporting of Greenhouse Gas Emissions (MRR)
Mandatory GHG emissions reporting data was originally required by the California Global Warming Solutions Act of 2006. Industrial sources, fuel suppliers, and electricity importers must submit data to the California Air Resources Board (CARB). Organizations that are captured under California’s Cap-and-Trade program must have their data verified by a third party CARB-accredited verification body. The MMR has been subject to numerous updates and revisions since its founding. It is critical for obligated organizations of all programs to stay up to date on changes as they can have major impacts on the reporting process.
Oregon Mandatory Greenhouse Gas Emissions Reporting
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. Verification requirements began in 2022 for 2021 data. Verification generally applies to large facilities and suppliers submitting reports with GHG emissions equal to or greater than 25,000 metric tons of carbon dioxide equivalent (MTCO2e) in the prior calendar year.
The GHG Reporting Process
If you have determined that your facility or operation is subject to GHG regulation (or likely to be captured in the future), the first step is to understand how the regulation applies to your organization. Programs can differ drastically in what is allowed or required to be reported.
Beyond the simpler question of which sources and fuels (as well as other operational information) may need to be reported, you need to know whether your data capture systems are sufficient to meet your compliance obligations; and if they are not, knowing the alternative approaches is crucial. For example, before spending thousands of dollars on new metering equipment, check to see if your third party fuel consumption invoices are sufficient.
Once the basic requirements and calculation methods have been identified, the next step is to gather your data. Ideally, existing systems will meet your GHG reporting requirements. If not, you should proactively check for data gaps and regulatory compliance requirements with sufficient time before reports are due.
The recent ruling by the Security and Exchange Commission (SEC) obligates corporations to disclose a myriad of climate-related disclosures including direct and indirect emissions.
Read more about GHG verification and carbon management obligations here.