Amendments to Greenhouse Gas Emissions Reporting

The Ontario Ministry of Environment and Climate Change (MOECC) finalized amendments to the Greenhouse Gas Emissions Reporting Regulation (O. Reg. 452/09) which came into force on January 1, 2016.  The amendments to O. Reg. 452/09 were deemed necessary to support a cap-and-trade program, which the MOECC proposes to finalize in spring 2016.

Background on O. Reg. 452/09

The Greenhouse Gas Emissions Reporting Regulation (O. Reg. 452/09) came into force on January 1, 2010.  The purpose of this regulation was to track and report GHG emissions to create baseline GHG emissions information in preparation for a future GHG cap-and-trade program.  As of the 2010 calendar year, all facilities emitting over 25,000 tonnes of GHG per year, in terms of carbon dioxide equivalents (CO2e), were required to report their emissions by June 1 of the following year.  For facilities meeting the 25,000 tonne reporting threshold, third party verifications of the emissions were required, starting with the 2011 GHG emissions.

Facilities that emitted less than 25,000 of GHG are not required to report however, may report their GHG emissions voluntarily.  After coming into force several amendments were made to the regulations since 2010.

Summary of Amendments to O. Reg. 452/09

Some of the amendments to O. Reg. 452/09 that came into force on January 1, 2016 include:

  • Lowered emissions reporting threshold from 25,000 tonnes of GHG per year to 10,000 tonnes of GHG per year for Table 2 activities listed in the regulation.  The lower reporting threshold is in line with the reporting thresholds used in other jurisdictions that have currently implemented the cap-and-trade program.  The emissions threshold at which the emissions report is required to be verified remains at 25,000 tonnes of GHG emissions.  The third-party verification is used to evaluate the emissions report to determine any errors in measurements and calculations, and if the report was prepared according to rules and guidelines.
  • Dividing the emission sources into those that only need to report (non-capped emission category) and those that require third party verification (capped emission category).  The emission sources in the non-capped category (i.e. not required to report) are not subject to potential compliance requirements under a cap-and-trade program.
  • Adding petroleum product suppliers to the reporting regulation starting in 2016, to support the implementation of a cap and trade program.  Petroleum product suppliers are required to report the volume of products introduced into the Ontario market and the GHG emissions that would result from the combustion of that fuel.  The reporting threshold for liquid petroleum fuel distributor/supplier is set at 200 litres, similar to the Quebec requirements.
  • Adding other sources to the reporting regulation.  These new sources are now required to report GHG emissions.

Transitional Period

  • New activities introduced by the amended regulation:  In the first year (i.e. 2016 emissions report to be submitted by June 1, 2017), the emissions from the activities can be quantified using either the Standard Quantification Methods (SQM) for these new sources or one of the best alternative methods listed for that source.  The verification of the reported emissions is voluntary in the first year.  In the second year and all subsequent years, it is mandatory for the emissions from the activities to be quantified using the SQM for that activity.  Verification of the emissions report for 2017 and all subsequent years is also mandatory.

Implications for Manufacturing Companies in Ontario

The lowered reporting threshold of 10,000 tonnes of GHG will require many facilities that have not reported GHG emissions in the past to be reportable for GHG emissions in subsequent years.  In addition, new activities introduced by the amended regulation have Standard Quantification Methods that are mandated to be used for emissions quantification by the second year.  The mandated quantification methods may be different from the methods currently used for these activities, and would require revisions.

GHG Emissions Verification

Verification of GHG report must be completed by an accredited third-party organization.  The verifying organization is ultimately required to develop a verification report, and provide the facility with a verification statement to confirm the review of the GHG report.  The facility, in turn, is required to submit this verification statement through Environment Canada's Single Window Information Management (SWIM) portal.  The deadline for facility to submit the verification statement is September 1 for the previous year reporting period.

Trinity Consultants is highly qualified in assisting facilities with quantification and verification of GHG emissions and reporting.  Trinity is a fully accredited AB32 Verification Body, with more than 50 offices in Canada and U.S., including Toronto, and 4 offices located in the state of California.  Trinity completes approximately 50 GHG verification projects on an Annual Basis.

Trinity Consultants has the knowledge, experience and resources to assist your facility in developing and implementing a GHG management program.  For more information, please contact Suzy Sabanathan at (416) 391-2527 x22.