Tech Environmental e-Newsletter
December 2011

GHG VERIFICATION FOR AULD LANGE SYNE

As 2011 comes to an end, the largest Greenhouse Gas (GHG) emitters in Massachusetts are completing their first GHG verification processes by third-party entities approved by MassDEP.  This mandatory exercise has caused additional costs and efforts for these facilities to comply with this requirement.  Our clients' recent experiences have shed some light on the intricacies of the verification process. 

The verification process is an audit of the most recent GHG reports submitted to MassDEP.  This triennial verification process will be required of even more Massachusetts facilities in 2012 and 2013.  Accurate and suitable recordkeeping in 2011 and 2012 will lead to acceptable reporting and will minimize time spent and expenditures associated with the verification process. 

The timeline and costs involved with the verification process vary by facility, and depend on how “verification ready” each facility is.  It is likely this process will be iterative when verifiers discover inconsistencies in data, underreporting of emissions, or that the method of emission estimation is not apparent in the facility’s recordkeeping. Therefore, it is important that facilities accurately document their GHG emissions data to the fullest extent practicable, otherwise any omissions or shortcomings in data acquisition could be discovered during verification.

Some of our clients are in the process, or have recently fulfilled, their first GHG verification requirement.  Some common discrepancies discovered or requested by verification bodies have included:

• Omitted sources of HFCs associated with refrigeration and/or compressed gases;

• Omitted sources of SF6 associated with electrical transmission equipment;

• Justification for grouping GHG emission sources together; and

• Justification for using a lower emissions tier for reporting.

The deadline for completing the verification process, and if necessary submiting a revised GHG report to MassDEP, is December 31st.  This year’s deadline is only applicable to facilities who reported more than 25,000 short tons of carbon dioxide equivalent (CO2e) emissions in 2010.  Those facilities emitting more than 10,000 short tons in 2011 will be required to have their GHG reports verified by the end of 2012, and all other reporting facilities must have their 2012 reports verified by the end of 2013. 

Tech can help you with the new regulations by preparing GHG report submittals or assisting with recordkeeping preparation. Third-party verification is here: penalties are still being determined, so it is best to make sure that your facility is properly collecting all applicable GHG emissions data right now.

Tech Environmental has been calculating air emissions for 25 years: we have kept many clients in compliance with all applicable regulations, and we have worked closely with MassDEP. Tech provided oversight during the development of Mass. GHG regulations, and we've worked with many clients to report GHG emissions and mitigate GHG impacts.

For more information, contact Dr. Dana Buske at dbuske@techenv.com.

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