California AB 32 Verification Services
Many organizations in California are required to report and reduce greenhouse gas (GHG) emissions mandated by California Global Warming Solutions Act of 2006 (AB 32). In December 2007, the California Air Resources Board (ARB) promulgated AB 32 mandatory reporting regulations (MRR) requiring organizations to measure, calculate, report, and verify their greenhouse gas emissions if they are in selected industry sectors or are a general stationary combustion (GSC) source generating greater than or equal to 25,000 metric tons (MT) of CO2 per year. In 2010 and 2012, ARB made significant amendments to the original 2007 version of GHG MRR in an effort to harmonize the reporting requirements with EPA 40 CFR Part 98 and to support the new California Cap-and-Trade regulation. The most recently amended (2012) version of MRR became effective on January 1, 2013.
Mandatory reporting is intended to provide information that will assist ARB in the development and implementation of strategies to restore GHG emissions to 1990 levels by the year 2020. Third party GHG verification is being required under the AB 32 regulation to ensure the reported emissions and product data are accurate and independently verifiable. Mandatory third party verification is necessary as reported GHG and product data have a direct effect on the newly adopted Cap and Trade Program. Verification is not required for sources that meet criteria of “abbreviated reporters” but is required for all sources subject to the amended ARB GHG MRR and not eligible for abbreviated reporting for the 2011 GHG inventory or later. The frequency of required third-party verification services is annual. Verification statements are due to ARB by September 1 for all non-abbreviated reporting facilities regardless of reporting deadline dates. With this aggressive deadline of third-party verification requirement, ARB strongly urges reporters to be engaged with prospect verification bodies to move forward with contractual process and actual verification activities in a timely manner.
Trinity’s AB 32 GHG Verification Service Group is uniquely qualified to assist with AB 32 verification by identifying and verifying entity boundaries, emissions sources, emissions factors, electricity transactions, product data reviews, measurements, and calculations to minimize material uncertainty in the GHG emissions data reported to ARB. Trinity’s AB 32 GHG Verification Group is an ARB accredited verification body with several accredited lead and sector specific verifiers in all sectors. Our AB 32 GHG Verification Services are conducted exclusively by ARB accredited Trinity verifiers, who have significant operational, GHG emission calculations, and verification experience. Our verifiers understand the reporting and calculations requirements and have in depth air quality experience with myriad complex industries including power/utility, refining, cement, hydrogen, electricity transactions, and other industries potentially affected by AB 32. This experience enables Trinity to verify more than just the system through which data is gathered, instead providing an in-depth technical review of the GHG inventory and product data to minimize reporting uncertainty.
Understanding the Verification Requirements
Under the amended ARB GHG MRR, most facilities will likely report only CO2, CH4 and N2O as annual facility level GHG emissions. The power entity (electricity sector) will no longer be required but will have an option to report SF6 and HFCs via the ARB’s new reporting tool (Cal e-GGRT). There is no third-party verification obligation for those optional SF6 and HFCs emissions reported into Cal e-GRRT. Direct stationary combustion emissions, specified process and fugitive emissions, fuel usage by fuel type with biomass fuels included separately, disposition, purchase, sale of energy, and indirect energy usage reporting continue to be mandatory. The de minimis emissions level continues to be 3%, not to exceed 20,000 metric tons of CO2e annually.
For 2012 or later emission data, specified methods described in the amended ARB GHG MRR must be followed for monitoring, calculations, and missing data substitution.
Partnering with Trinity Consultants
Our AB 32 GHG Verification Services Group consists of environmental professionals with engineering backgrounds, most with advanced degrees and professional certifications. Our multi-disciplined staff provides the highest quality verification services that enhance regulatory compliance while maximizing operational flexibility.
Trinity’s AB 32 GHG Verification Team is listed below along with their accredited sectors.
Trinity helps its clients achieve verification by combining regulatory expertise, technical proficiency, responsiveness, and creative thinking. Trinity’s Quality Management System (ISO 9001 certified at its Dallas, TX headquarters location) ensures that clients consistently receive high quality verification services. Trinity’s AB 32 GHG Verification team provides the following unique
benefits to our clients:
- Partnering with a recognized leader in air quality and climate change issues and one of the most active ARB accredited verification bodies in the California GHG verification service market
- Access to experts on AB 32 reporting, verification, and Cap-and-Trade
- Availability of experienced ARB accredited verifiers (general and all sector specific verifiers) and staff to provide verification statements quickly and cost effectively
- Experience in developing verification and sampling plans, reviewing GHG inventory requirements, conducting site visits, reviewing emission and product data and methodologies, and reviewing GHG emission calculations, resulting in effective completion of AB 32 verification services and opinions
- An in-depth understanding of the industry sectors affected by the AB 32 requirements — our verifiers speak the language of your industry sector and understand the unique challenges of your sector
- Extensive experience performing compliance and system audits for clients in a professional, efficient, and beneficial manner
For more information about Trinity’s AB 32 GHG Verification Services, please contact our Irvine office at (949) 567-9880 or our Bakerfield office at (661) 282-2200.
For assistance, contact your local Trinity office at (800) 229-6655.