Environmental Permitting

Understanding GHG Sources From Low Emitters

In 2012, the Environmental Protection Agency’s (EPA’s) Greenhouse Gas (GHG) Reporting program tallied the emissions of more than 8,000 facilities and suppliers that totaled 3.13 billion metric tons of carbon dioxide equivalent emissions. That is, about one half of all GHG emissions produced nationwide were accounted for, categorized by source and summarized in a report. But what about the other half?

In the United States, an estimated 23 million small businesses are in operation, a number that has increased 49% since 1982. This number encompasses everything from franchised fast-food restaurants to retail shops and business offices and occupies 30-50% of commercial space, totaling approximately 20-34 billion square feet.

It might seem silly to think of the local sub shop or automotive mechanic as GHG sources, but the fact is, every business that uses energy from combusted fuel, also directly or indirectly emits GHGs. Known as “low emitters” in the regulatory scheme, these facilities are cumulatively responsible for a fair share of the remaining half of GHG emissions, even though individually they do not meet regulatory reporting thresholds. In lieu of waiting for the regulatory ax to fall on them, however, there are many things for low emitters to understand about how they are contributing to the problem and what they can do to become part of the solution.


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To understand GHG potential, it is helpful to define the different direct and indirect GHG emission sources. Direct emissions are from sources a company owns or controls, such as boilers for heating, air conditioning equipment, and even business-related travel when the company picks up the tab for fuel costs. The EPA categorizes five types of direct sources, although many small business may have few or none:

  • Stationary combustion – water heaters, boilers, etc.
  • Mobile sources – cars and heavy-duty vehicles that burn fuel
  • Refrigeration and air conditioning equipment – these may leak GHG chemicals
  • Fire suppression equipment – emit GHGs during use, maintenance or disposal
  • Process emissions – not typically applicable to low emitters
  • Other sources – including backup generators, corporate aircraft, etc.

Indirect emissions or those resulting from a facility’s use of energy that is generated by another company that is the direct source, such an electric or natural gas utility. Notably, purchased electricity is often a facility’s greatest source of GHG emissions and thus represents the biggest opportunity for reducing GHG emissions. The EPA categorizes indirect purchased power as:

  • Purchases of electricity
  • Purchases of heat or steam

Join us for an in-depth webinar on February 26. When our speakers, seasoned environmental professionals who have helped many companies develop and implement practical GHG management strategies, will provide participants with a straight-forward approach to establishing a process that not only meets regulatory requirements but also identifies potential cost-saving opportunities.


In addition to direct and indirect emissions sources, the EPA also recommends low emitters consider several optional emissions sources to assess possible ways to lower GHG emissions. These include:

  • Employee business travel – optional travel not accounted for as a direct emission source such as travel via air, rail, taxi, or other vehicles not owned by the company.
  • Employee commuting – includes employee commutes using personal vehicles, as well as mass transportation such as buses or trains.
  • Product transport – when provided by another company.

This information provides the basis for using two EPA-sponsored tools, the Energy Star Portfolio Manager and the Climate Leaders Calculator. The Energy Star Portfolio Manager is a secure interactive energy management tool that helps users track and assess energy consumption company wide. This data and information can also be moved into the Climate Leaders Calculator which  calculates GHG emissions for the company, creating a baseline GHG inventory and a means of tracking annual emissions year to year. To begin assessing your GHG potential, start with the Portfolio Manager at http://www.energystar.gov/.