Environmental Permitting

Why You Should Participate in Voluntary GHG Reporting


A second term for the Obama administration will likely cause the universe of regulations governing GHG emissions to expand, both at the federal and state level. Therefore, an understanding of current facility GHG emissions will facilitate applicability determinations and compliance and, in some instances, may allow actions to be taken to avoid applicability.

In addition to regulatory compliance, involvement in GHG management programs may enhance a company’s bottom line in ways that are both qualitative and quantitative. For example:

  • Situations may be identified in which the proactive implementation of a program or strategy to reduce GHG emissions could allow the company to gain revenue through the generation and sale of emissions reduction credits or gain a competitive advantage in the event of future regulations.
  • Participation in an industry coalition, U.S. Environmental Protection Agency (EPA) program, or initiation of an internal GHG management program may enhance the company’s reputation as a good corporate citizen.
  • The most common source of GHG emissions is energy consumption in the forms of fossil-fuel combustion and electricity usage, which equates to a significant cost at most facilities. Therefore, GHG management strategies aimed at improving efficiency, thereby reducing energy consumption, will result in lower operating costs at the facility.

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Why Should You Participate in Voluntary GHG Reporting?

The first step in the implementation of a GHG management program is for your company to realize one or more of the aforementioned qualitative and quantitative advantages is the compilation and reporting of a GHG emissions inventory.  The preparation and submission of such reports:

  • Establish an official record of your entity’s GHG emissions and reductions;
  • Provide the impetus for improving the GHG emissions monitoring and management program at your entity;
  • Provide tangible evidence of the results of your entity’s commitment to reduce GHG emissions; and
  • Prepare your facility for the future by document reductions for use under any future incentive-based or mandatory climate change programs.

Mandatory vs. Voluntary

The EPA regulations under 40 CFR 98 clearly specify what sources are required to report GHG emissions and establish provisions identifying the following for each source:

  • Reporting thresholds
  • GHGs that must be reported
  • Methods of calculating applicable GHGs
  • Monitoring and quality assurance/quality control (QA/QC) requirements
  • Procedures for estimating missing data
  • Reporting requirements
  • Recordkeeping requirements

For sources not required to report, calculation and reporting of GHG emissions must done in a manner that allows the information to be useful, both now and in the future.  Therefore, it is a good idea for such sources to join an organization such as The Climate Registry, which is a nonprofit entity that seeks to “serve as a centralized repository of high-quality, accurate, transparent, verified GHG emissions data for the public.”


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Participants in the Climate Registry must report their GHG emissions (CO2, CH4, N2O, HFCs, PFCs, and SF6) throughout North America at the facility level, and those emissions must be audited and verified by a third party. To facilitate the process, the Climate Registry provides guidance and an online software application for calculating, reporting, and verifying emissions. 

In addition to enhancing your company’s image as a good corporate citizen, participation in an organization such as the Climate Registry will provide credibility to your GHG emissions data and calculation methods, which may make things easier down the road.

See tomorrow’s Advisor for information about GHG emissions inventories.

Other Resources:

The EPA denies adding GHG rules