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At its September 22, 2016 public hearing, California Air Resources Board (CARB) staff presented amendments to California's existing Regulation for the Mandatory Reporting of Greenhouse Gas Emissions (MRR). On December 21, 2016, staff released a Notice of Public Availability of Modified Text (Notice). Comments that were received during the formal public comment period for the modified text, as well as further staff analysis, are reflected in proposed modifications in a second 15-day Notice. On April 13, 2017, CARB released the second notice of 15-day modifications. A final regulation order was finalized and submitted to the Office of Administrative Law for approval by September 1, 2017.

Key changes of the Final Order include:

  • Verification deadline moved from September 1 to August 10 of each year, starting 2018.
  • Updated global warming potential values will be used starting 2021 data reported in 2022.
  • Facility schematic diagram indicating fuel flows and metering locations will be required as part of GHG monitoring plans.
  • For applicability, liquefied petroleum gas (LPG) and liquefied natural gas (LNG) changed the point of regulation from "consignee" to "importer".
  • For petroleum and natural gas systems, CARB clarified the use of a default value for combustion efficiency for calculating engine emissions. CARB also clarified the existing flash emissions test in Appendix B.
  • For fuel suppliers, biomethane was clarified for reporting by a utility.
  • For electric power entities, clarifications were made to California Independent System Operator (CAISO) sales and other minor revisions.

If approved, these changes will impact the applicability, monitoring, and calculations for the facility types mentioned above. The updated global warming potentials will not affect facilities during the current compliance period. The verification deadline will place more pressure on verification bodies to complete verifications sooner, which places pressure on reporters to move up certain timelines, such as selecting a verifier, site visits, and providing information.

Please contact your local Trinity office for more information. The final order can be found here.