Updates: 2016 GHG Emission Regulations and Single Window Reporting System -- February 2017
1.Delayed Verification
What is delayed verification?
Delayed verification is when a Reporting Operation supplies Verification Statements for 2 consecutive reporting periods by the date the Emission Report for the second Reporting Period is due.
Who does this apply to?
Delayed verification, under section 28 (3) of the Regulation, applies to Reporting Operations with Verification Statements for the last 2 consecutive periods that were positive without qualifications, and have not had significant changes to process or activities, or significant physical changes, at the reporting operation. Delayed verification does not apply to the regulated operations.
What is considered a significant change?
The following changes are considered significant:
For Single Facility Operations:
New processes, activities, or physical changes are considered significant
Replacement processes, activities or physical changes are considered significant if any of the following is true compared to the previous year’s emission report:
Change in production capacity is greater than 5%
Change in emissions after adjusting for energy inputs (fuel amounts etc.) is greater than 5%
Linear Facilities Operations:
New processes, activities or physical changes are considered significant if any of the following is true compared to the previous year’s emission report:
Change in total production capacity is greater than 5%
Change in total emissions after adjusting for energy inputs (fuel amounts etc.) is greater than 5%
Replacement processes, activities or facilities are not considered significant changes
The maximum production capacity should be calculated based on the equipment specifications as rated by the manufacturer.
What reporting year can delayed verification can be applied?
Delayed verification can be applied to the 2016 Reporting Year.
How does delayed verification impact the number of consecutive years a Verifier can work with an operator?
Section 26 of the Regulation provides that a verification body may not perform verifications of emissions reports for an operation in 6 of 9 most recent calendar years. If a Verification Body has performed 5 consecutive verifications, the Verification Body may provide verifications for the 6th and 7th year concurrently. The verification body cannot provide any further verification until the number of performed verifications again satisfies the “6 out of last 9 most recent calendar years” rule.
What are the requirements of the “statement” that an Operation Representative must provide in order to qualify for delayed verification of an Emission Report?
The Operational Representative must move a statement certifying that the operation meets the requirements as set out in Section 28 (3) of the Regulation. An Operational Representative must certify the last 2 consecutive reporting periods were positive without qualifications, and that there have been significant changes to process or activities, or significant physical changes, at the reporting operation.
Is there a standard form for this Statement?
There is currently no standard form for this statement.
Is there a place in SWIM to upload the document?
The statement can be uploaded to the comments page on the Single Window System located at the end of an emission report.
What happens if the facility production capacity or emissions are reduced by more than 5%?
The Reporting Operation may apply delayed verification.
2.Administrative Penalties
Do administrative penalties apply to Verification Reports that come back with an Adverse Opinion or No Opinion?
If a Verification Statement associated with an emissions report contains adverse or no opinion, the Reporting Operation would be in contravention of section 3 (2) of the Act which provides that an operator of a reporting operation must ensure that a verification statement for an emission report is submitted in accordance with the Regulation. The GHG Reporting Regulation requires that a verification body provide a statement of opinion that the assertions in the emission report are materially correct and a fair and accurate representation of the reporting operation’s emissions which have been prepared and quantified in accordance with the Regulation. Failure for the reporting operation to meet the verification requirements may result in an administrative penalty.
3.Methodologies
Have there been any updates to the Western Climate Initiative (WCI) Quantification Methodologies?
There is no update to the WCI methodology at this time.
A field for General Stationary Combustion was added to “measured emission factors” in SWIM. What are the requirements surrounding the need to use measured emission factors?
The “Measured Emission Factor” was added in an earlier early reporting cycle. This year “Measured Emission Factor Unit” was added to the system in order to ensure complete information is provided on measured emission factors. Examples of emission factor units are Kg CO2 per tonne of fuel or t CO2 per tonne of fuel, or kg CO2 per kilolitre of fuel. The requirement is dependent on the type of fuel and the methodology used.
4.Deadlines for Reporting and Verification
When is the deadline to submit Emission Reports, Compliance Reports and verification statements?
All emission and compliance reports must be submitted on or before May 31 for the prior reporting year. Emission and compliance reports must be submitted each Reporting Period. If required, verification statements accompanying emissions reports must be submitted on or before May 31. Verification statements for compliance reports are required on or before May 31.
5.Compliance Reports
What is a Compliance Report and how do they apply?
Compliance Reports are only required for Regulated Operations. Currently only LNG Operations are regulated. A Compliance Report is built on an Emission Report and includes additional requirements such as the amount of electricity used, total attributable emissions, production information, difference between emissions and emissions limit, and statements of compliance units available in the operator’s BC Carbon Registry account.
6.Supplementary Reports
What is a supplementary report?
Supplementary reports address omissions, inaccuracies or changes to the reports originally submitted by a Reporting Operation or a Regulated Operation. Supplementary reports must be submitted within 60 days of an operator becoming aware of an omission, inaccuracy or change in information. The Regulation provides supplementary reporting requirements for emission reports (s. 18) and compliance reports (s. 24).