A Systematic Approach to Ensure a Successful Greenhouse Gas Verification

Greenhouse Gas Verification

After Assembly Bill 32 was signed into law by the California legislature in 2006, the emphasis shifted into the mechanics and implementation of the program and what it would mean for the facility that was now subject to reporting their greenhouse gas emissions and ensuring these reported emissions were successfully verified. There was, and still is, considerable consternation on the part of the facilities as to what would be the most effective and cost efficient approach to organize their greenhouse gas emissions data collection, analysis and recordkeeping process in order to ensure a painless verification process. ALG has been involved in the greenhouse gas reporting program from its inception and has been on both sides of the aisle; providing reporting and verification services. This article draws on our considerable experience and offers some practical suggestions on how to make the verification process as painless as possible for any facility that is subject to reporting and verification per the AB32 regulation.

Organize, Organize, Organize!
Effective organization of your data cannot be emphasized enough. This applies equally to a facility with a simple combustion unit that burns utility supplied natural gas or a complex petroleum refinery or oil and gas facility with multiple emission and process sources. The conceptual goal of data organization is to establish a protocol that would make the product verifiable. Here is what I mean by that: If you have twelve months of natural gas consumption from your utility supplier, start a spreadsheet that has all the months of the year, the account number(s), meter number(s), volume of natural gas supplied, high heat value or billing factor and any other pertinent information. If you have multiple meters reading flow volumes to multiple units, have an information page (i.e. a Readme type document) attached or as a part of the data collection spreadsheet that describes your system in detail. This information is critical to your verifier and having this clearly described and organized will result in a smoother verification process. The same approach should be implemented even if you multiple sources; it would take more time and effort on your part initially but in the long run, it would be of great benefit to you during the reporting and verification process.

Data Format
Microsoft Excel is an extremely convenient and efficient way for you to organize your data, insert equations and macros to perform emission calculations and it provides a level of transparency and easy accessibility during the verification process. This is also the case for other programs such as Access. The key point is to use a program that is fairly common to most users as a complex and facility unique program would only result in the verifier coming back to you with multiple questions and requests for easier data access. So, keep it simple.

Step 3: Where Did I Save That Again?
Once you are done with organizing your raw data into spreadsheets, performing all the calculations, reporting to Cal e-GGRT, you are now ready for verification, or are you? Surprisingly, a large number of facilities do not organize their electronic files on their computer or server in a systematic manner. Make it a habit to create folders for each emission source or group of units that combust a common fuel (for example) and keep all raw data, spreadsheets, Readme files associated with a specific source in that folder. This way, when needed during the verification process, you will have immediate access to all the pertinent information related to a specific emission source. This saves you time and reduces the amount of searching you would otherwise be doing during the very intense verification process. Verifiers are a patient lot but no one likes having to send multiple emails requesting various data files related to a single emission source and certainly no one like receiving multiple emails from their verifier on a daily basis.

Step 4: Time Is Not Your Friend
Currently the verification process starts after April 10th and ends September 1st. Starting 2018, the verification deadline is shortened to August 1st. What does this mean for you? It means that it is essential you make your verifier's request for data, clarification, and response to Issues Log a priority. Remember, if you are tardy in responding because you have ten other non-related issues to attend to, your verification process is essentially halted until you find the time to respond. So, please find the time by making the verification process an equal priority or through delegation. Of course, if you follow Steps 1, 2 and 3 your verification process should be clicking along smoothly with potentially, just a few bumps along the way.

Step 5: Be A Hoarder (of Data)
It is never a good idea to be a hoarder, unless it relates to greenhouse gas reports. All data, reports, verification reports must be maintained in an easily accessible location for ten years. A lot of things happen in ten years; retirements, new hires, transfers. It is imperative that these records be maintained in a location that is known to more than one person at your facility. The Air Resources Board can and does perform retroactive audits on these records and you want to be prepared if that should occur.