BlueScape AB32 GHG Reporting in California: What has Changed for 2014? Webinar 2-27-14

AB32 GHG Reporting in

California What has changed for 2014?

February 27, 2014

Tracy V. Haynes, PE [email protected]

619-972-3443

Agenda

•  Why is the MRR changing again? •  What can go wrong if I don’t get it right?

•  Overview of MRR changes •  EPA GHGRP – Recent Developments •  Cap-‐and-‐Trade updates •  AB32 Scoping Plan updates •  Summary •  QuesLons

About BlueScape

•  17 years experience, full service firm specializing in air quality services

•  PermiUng, dispersion modeling and compliance for many industries

•  Project experience on GHG issues including reporLng for AB32, EPA and voluntary registries

Why is the MRR Changing Again?

•  Mandatory GHG reporLng supports AB32 goals

•  Further align with EPA GHGRP •  Provide clarificaLon, maintain accuracy, and demonstrate progress in reducing emissions

•  Support Cap-‐and-‐Trade implementaLon

What Can Go Wrong if I Don’t Get it Right?

•  Accurate reporLng is criLcal to your company’s boXom line

•  ARB is ramping up enforcement, fines are heavy

•  $1MM in fines issued to Chevron and Southwest Gas Corp for inadvertent reporLng mistakes (ARB Press Release #14-‐06)

•  Nine other companies fined between $10,000 -‐ $120,000 for late and/or incomplete reporLng (ARB Press Release #13-‐39)

MRR – What are the Changes?

•  Include clarificaLons, methodology changes and addiLonal requirements

•  General Applicability •  Electricity GeneraLon and Cogen •  Other ReporLng EnLLes •  VerificaLon •  CessaLon of ReporLng •  Notes from ARB

General Applicability •  New industry sectors added:

–  Lead ProducLon –  LNG ProducLon faciliLes –  40 CFR Part 98 Subparts Applicable if >10,000 MT CO2e:

•  E: Adipic Acid ProducLon •  F: Aluminum ProducLon •  G: Ammonia Manufacturing •  I: Electronics Manufacturing •  K: Ferralloy ProducLon •  L: Fluorinated Gas ProducLon •  O: HCFC-‐22 ProducLon and HCFC-‐23

DestrucLon •  R: Lead ProducLon •  T: Magnesium ProducLon •  U: Miscellaneous Uses of Carbonate •  X: Petrochemical ProducLon •  Z: Phosphoric Acid ProducLon

•  BB: Silicon Carbide ProducLon •  CC: Soda Ash Manufacturing •  EE: Titanium Dioxide ProducLon •  FF: Underground Coal Mines •  GG: Zinc ProducLon •  II: Industrial Wastewater Treatment •  LL: Suppliers of Coal-‐Based Liquid Fuels •  OO: Suppliers of Industrial GHG •  QQ: Importers and Exporters of

Fluorinated GHG in Pre-‐Charged Equipment or Closed-‐Cell Foams

•  SS: Electrical Equipment Manufacturing or Refurbishment

•  TT: Industrial Waste Landfills

Reference: §95101(a)

General Applicability •  Applicable industrial processes must noLfy ARB within 90 days of 1/1/14 or within 90 days of commencing the process (§95101(a)(1)(G))

•  Recently updated ARB guidance documents available to assess applicability hXp://www.arb.ca.gov/cc/reporLng/ghg-‐rep/guidance/guidance-‐docs.htm

Reference: §95101(a)

Title

•  Insert text

General Applicability •  ClarificaLons for calculaLng GHG relaLve to thresholds:

Threshold Include

25,000 MT CO2e (§95182 Cap-‐and-‐Trade)

All covered emissions of CO2, CH4 and N2O

10,000 MT CO2e (§95101(a) ReporLng)

CO2, CH4, N2O from staLonary combusLon and process

emissions. Exclude any vented and fugiLve emissions.

25,000 MT CO2e (§95103(a) Abbreviated

ReporLng and (f) VerificaLon)

All CO2, CH4 and N2O emissions within facility boundary, including

vented and fugiLve

•  Hydrogen fuel cell unit operators must include these emissions in applicability calculaLon

Reference: §95101(b)

General Applicability •  Common control versus common ownership:

–  Basis can only be changed at the beginning of a compliance period.

–  Does not apply to legal change in facility ownership •  GHG Monitoring Plan

–  Now required for all faciliLes with emissions >25,000 metric tons

•  CessaLon of ReporLng –  95101 (h) Clarifies that cessaLon only applies to

faciliLes without a Cap-‐and-‐Trade obligaLon •  CessaLon of VerificaLon

–  FaciliLes wishing to cease verificaLon must noLfy ARB

–  FaciliLes with a Cap-‐and-‐Trade obligaLon must obtain verificaLon

References: §95101(a), (h), (i), 95015 (c)

Emissions Data ReporLng Requirements and Report Contents

•  For aggregated reporLng of mulLple unit types, report % of fuel aXributed to each unit type

•  Requirement for faciliLes with more than one cogen, boiler or steam generator to report disposiLon of generated thermal energy by unit

•  New requirement for Cap-‐and-‐Trade faciliLes to report if a change in facility operaLons or status results in a +/-‐5% change in emissions

•  Changes in facility air permit must be disclosed References: §95103(a)(2), 95104 (d), (f)

Electricity GeneraLon and Cogen •  Best Available Methods (BAM) for some data elements for 2013 report

•  Requirements for reporLng electricity used to produce cooling energy or thermal energy

•  Requirement to report disposiLon of generated electricity by unit or system for end users

•  Subpart D reporters must report CO2 generated from sorbent injecLon

•  ClarificaLon to requirements for missing data subsLtuLon procedures

References: §95112(a), (c), (h)

Other ReporLng EnLLes •  Electric Power EnLLes -‐ Warranty requirement for

sellers of specified power

•  Supplementary data reporLng requirement for local distribuLon companies that report biomass from biomethane fuel delivered to end users

•  Product data requirements updated to assist with cap-‐and-‐trade allowance allocaLon, new definiLons

•  Updated emissions esLmated methods and data reporLng requirements for faciliLes including petroleum and natural gas producers, refineries, and manufacturing sectors

References: §95111(a), 95122 (d), 95102 (b), 95113, 95117, 95150

VerificaLon •  Full verificaLon required for change in operaLonal control

•  Specifies restricLons for the 6-‐year verificaLon limit

•  Added requirements for verifiers to confirm informaLon such as natural gas supplier account numbers and MMBtu reported

•  Verifiers are required to confirm no subsLtuLon for product data References: §95130(a),(b), 95131(b)

Notes from ARB •  Training webinars likely 2nd week of March •  Use the previous Global Warming PotenLals •  Complexity Weighted Barrel and Subpart W spreadsheets will be posted soon

•  Hydrogen producers product entry currently disabled

•  Subparts C and D, de minimis emissions reported with combusLon instead of Subpart A

EPA GHGRP Developments •  Pending rule change to Subpart W – Petroleum and Natural

Gas Systems –  CalculaLon methods –  Monitoring and data reporLng requirements –  Terms and definiLons –  Technical and editorial errors

•  Final 2013 revisions effecLve 1/1/14 –  Amendments to Global Warming PotenLals –  Minor amendments to mulLple subparts –  ConfidenLality determinaLons

•  Some reporLng elements deferred for evaluaLon regarding “confidenLal business informaLon” – 2013 and 2015

Cap-‐and-‐Trade Status

•  StaLonary combusLon and electricity generaLon in first compliance period – 2013/2014 – 35% of GHG

•  Fuel distributors beginning in 2015 – 85% of GHG •  Emissions in most sectors going down, HFCs going up – ARB plans to address in 2015

•  Common reporLng plauorm with Quebec, eventually linked aucLons

•  MulLple lawsuits sLll pending

AB32 Scoping Plan Update •  Proposed drav of first scoping plan update recently released

•  IniLal plan focused on 2020; update sets a clear path toward long term reducLons

•  Integrated framework for achieving air quality and climate goals beyond 2020

•  PotenLal technologically feasible and cost-‐effecLve acLons to further reduce GHG by 2020

•  RecommendaLons for mid-‐term emission limit

•  Sector-‐specific discussions for reducing emissions

Key Dates and Deadlines •  February 1, 2014 – EPE deadline to register specified

sources

•  February 13, 2014 – Cal-‐eGGRT acLvated •  April 10, 2014 – ReporLng deadline for faciliLes and

fuel suppliers, except abbreviated reporters

•  June 2, 2014 – ReporLng deadline for EPE reports and abbreviated reports

•  July 15, 2015 – deadline for correcLons to RPS adjustment data required for EPE reports

•  September 2, 2015 – final verificaLon statements due

RecommendaLons and Summary •  Make sure reporLng is accurate and on Lme •  Start verificaLon process early, change verifiers aver 6 years

•  Use ARB resources if doing your own reporLng

•  Contact BlueScape for assistance with reporLng and verificaLon support for your facility

•  Stay tuned for future updates!

QuesLons?

Contact InformaLon

Tracy Haynes BlueScape Environmental

619-‐972-‐3443 [email protected] www.bluescapeinc.com

Connect with me on Linkedin! The webinar presentaAon will be posted on Slideshare (search for BlueScape)