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Third-Party (Independent) Verification Services under California Assembly Bill 32 (AB 32)

Third-Party Verification for California GHG Mandatory Reporting Regulation (MRR), Compliance Offset Program (COP), and Low Carbon Fuel Standards (LCFS)

Trinity's Verification Team has provided Greenhouse Gas (GHG) emission data verification services to a variety of industry sectors over a decade in California. Our verification services are conducted following applicable industry standards and/or regulatory programs, including but not limited to:

  • Regulation for Mandatory Reporting of Greenhouse Gas Emissions (Title 17, California Code of Regulations (CCR), sections 95100-95157)
  • Compliance Offset Program in the Cap-and-Trade Regulation (Title 17, CCR, sections 95801-96022)
  • Low Carbon Fuel Standard (LCFS) Regulation (Title 17, CCR, sections 95480-95503)
  • ISO Standards - Greenhouse Gases Part 3: Specification with Guidance for the Validation and Verification of Greenhouse Gas Assertions (ISO 14064-3:2019)
  • ISO Standards - Greenhouse gases - Requirements for greenhouse gas validation and verification bodies for use in accreditation or other forms of recognition (ISO 14065:2013)

Important Dates:

California GHG MRR - Verification Deadlines

  • August 10 - Final verification statements due for all emission data reports, including emissions, supplier data, and product data for all industry sectors (e.g., general, oil & gas, process, and transactions)

California COP - Verification Deadlines

  • The COP program does not include fixed reporting and verification deadlines, instead, it allows Reporting Periods to run over any 12-month period
  • All Offset Verification Statements are due to an Offset Project Registry within nine (9) months after the conclusion of the Reporting Period for which offset verification services were performed 

California LCFS - Verification Deadlines

  • August 31 - Final verification statements for all LCFS annual report types except for the following report types:
    • Fuel Pathway Applications - Validation statement is due within six (6) months of application submission to CARB
    • Quarterly Project Reports - If an entity chooses quarterly reporting, the verification statement is due within five (5) months of each quarterly project report deadline

What is Third-Party Verification Under California's AB 32?

California's Global Warming Solutions Act of 2006 (Assembly Bill 32 or AB 32) sets forth an aggressive program to reduce greenhouse gases (GHGs) from nearly every sector of the state's economy, including manufacturing, electricity, transportation, agriculture, consumer products, and others. The primary objective of AB 32 is to implement emission reduction strategies and programs that reduce GHG emissions to 1990 levels by the year 2020 initially, with additional reductions by the year 2050.

Third-Party Verification Requirements for GHG Mandatory Reporting Program (MRR)

As part of AB 32, the California Air Resources Board (CARB) promulgated mandatory reporting regulations (MRR) in December 2007 that require entities to calculate and report their GHG emissions for specific industry sectors and general stationary combustion sources with emissions greater than or equal to 10,000 metric tons (MT) of CO2e per year. Also, for those facilities with emissions that equal or exceed 25,000 MT-CO2e per year, accredited third-party verification is required (and AB 32 cap-and-trade obligations apply). The independent verification of GHG emissions data by an accredited verification body (VB) is an important element of ARB's MRR and cap-and-trade regulation to ensure reliable and accurate data.

Third-Party Verification Requirements for Compliance Offset Program (COP)

Compliance Offset projects can be used to generate GHG offset credits, which represent a removal or reduction of GHGs by a measurable, quantifiable, and verifiable activity. All compliance offset projects must be developed according to ARB-approved compliance offset protocols. To be eligible providers of ARB offset credits, offset project operators must register their offset projects with an approved offset project registry. Furthermore, offset projects must be independently verified by an accredited offset verification body, which has the required verification staff who are trained and accredited for the specific type of offset project. Once verified, the offsets generated from the offset project may be sold to AB 32 subject entities, who can use a limited number of offset credits to satisfy up to 8% of their annual compliance obligations under the cap-and-trade program.

Third-Party Verification Requirements for Low Carbon Fuel Standards (LCFS)

The main objective of LCFS is to decrease the carbon intensity of California's transportation fuel pool and to provide an increasing range of low-carbon and renewable alternatives, which would benefit air quality from reducing petroleum dependency. The LCFS relies on accurate data monitoring, reporting, and verification to support implementation and tracking of effectiveness. In 2018, CARB amended the LCFS regulation to add third-party verification requirements to ensure data completeness, accuracy, and conformance with the regulation, consistent with the verification programs under California's Cap-and-Trade Program and international best practices.

Trinity Can Help - Contact Us Today

Our CARB-accredited verification services are performed by experienced environmental professionals with engineering backgrounds, most with advanced degrees and professional certifications. Our multidisciplinary staff provides the highest-quality verification services that enhance regulatory compliance while maximizing operational flexibility. Trinity serves its clients through an unparalleled combination of regulatory expertise, technical proficiency, responsiveness, and creative thinking. Also, Trinity's Quality Management System ensures that clients consistently receive high-quality verification services and deliverables. Trinity's AB 32 GHG verification team provides the following unique benefits to our clients:

  • Accredited Verification Services: Trinity is an accredited verification body for MRR, COP, and LCFS programs. Our team includes experienced CARB-accredited lead verifiers and non-lead verifiers with specialist credentials in a wide range of industry and report types.
  • Proven Track Record: As one of the most active ARB-accredited verification bodies in California, Trinity completes more than 50 third-party verifications annually, with resoundingly positive feedback.
  • Recognized Industry Leader: Trinity is recognized as an industry leader in air quality and climate change issues.
  • In-Depth Knowledge: Trinity's team has extensive experience based on in-depth knowledge of industry practice, GHG emission inventories, and carbon footprint-related regulatory requirements.
  • High-Quality Work Products: Trinity's consulting and verification practices and operations are quality assured consistent with ISO 9001 standards for the delivery of superior technical products.
  • Relevant Project Experiences: Trinity has relevant experience in GHG verifications, GHG management, and emission reduction plans, enterprise-wide inventories, and carbon foot-printing, life cycle analysis, and fuet pathway development exercises for national and international corporations across various industry sectors and locations.
  • Cost-Effectiveness: Trinity offers cost-competitive project budgets and works efficiently using in-house checklists, protocols, and other tools developed during extensive GHG emissions verification/inventory projects.
  • Local California Offices: Fully staffed offices with accredited lead and non-lead verifiers are strategically located to cover the entire state, including Northern California, Central California, and Southern California.

For more information on how the Trinity can assist you, please contact: 

Third-party verification: Dr. Charles Lee, Principal Consultant - (949) 567-9880 x102

Other GHG-related assistance: Steve Walters, Principal Consultant - (949) 567-9880 x118

Related Services

In addition to the aforementioned third-party verification services, Trinity offers a wide variety of other climate change, sustainability, and GHG-related services:

  • ARB and EPA MRR reporting
  • Cap-and-trade forecasting and compliance
  • Cap-and-trade benchmark evaluation and rulemaking suppor
  • GHG verification in other programs and registries (e.g., CDP, CAR, and VCS)
  • GHG program training
  • GHG emission reduction plans 

Related Training

External Resources