Technical Guidance on Reporting Greenhouse Gas Emissions
Appendix A: Frequently Asked Questions (cont'd)
Q18 How are GHG emissions calculated by reporting facilities?
There are a number of methods that a facility may choose to use to calculate its GHG emissions. These include monitoring and direct measurement, mass balance, emissions factors, and engineering estimates. Reporting facilities must use methods for estimating emissions that are consistent with the guidelines adopted by the United Nations Framework Convention on Climate Change (UNFCCC) and developed by the Intergovernmental Panel on Climate Change (IPCC) (see Section 4.4).
Q19 Will any guidelines be issued on the estimation of GHG emissions for the reporting year?
There are no specific protocols developed for estimating GHG emissions that facilities must use; however, guidance is provided to assist reporters in categorizing emissions and in using the United Nations Framework Convention on Climate Change (UNFCCC) guidelines. This technical guidance document is designed to help potential reporters determine if they are required to submit a report. It also includes technical information related to GHG emissions to be reported and the required reporting format.
Help desk support is also available to facilities that may have questions on how to calculate their GHG emissions (see Q17).
Q20 If a reporting emitter adopts estimation or quantification protocols for future years that are different from those used in Phase 1, and if the resulting estimates of emissions differ significantly, how will the differing results be handled?
The purpose behind the phased approach to the development of the full domestic reporting system is to develop, test, assess and refine all aspects of reporting, including estimation and quantification protocols and methodologies. Until suitable methodologies and protocols are finalized, variations in results can be expected if there are changes in selected methodologies from one year to the next. It is important to recall that, as per the Canada Gazette notice, reporters must keep copies of the required information, together with any calculations, measurements and other data on which the information is based.
Q21 When reporting GHG emissions, is the requirement to report as a CO2 equivalent or the actual tonnage of each gas? For example, would I report 100 tonnes of N2O or 31 000 tonnes of CO2 equivalent units for N2O?
The reporter will be required to report the emissions of each individual GHG type, expressed in units of tonnes for each. For the example listed above, the reporter would report 100 tonnes of N2O.
Please note, however, that when a potential reporter is assessing whether he/she needs to submit a report, he/she will need to convert the emissions to CO2 equivalent units (CO2 eq) to compare them with the reporting threshold. The CO2 eq value is how much CO2 would be required to produce a similar warming effect, and it is calculated by multiplying the amount of the gas by an associated global warming potential (GWP). See Section 2.2 for a complete list of the GWPs for each GHG.
If the facility meets or exceeds the reporting threshold of 50 kt of CO2 eq for 2011, emissions for that facility must be reported.
Q22 Why does the pipeline definition refer to "pipeline transportation system" while the definition used for other emissions-reporting purposes in the National Pollutant Release Inventory (NPRI) refers to "pipeline installation"?
A pipeline is considered a mode of transport. For GHG reporting purposes, the concern is with both point-source emissions associated with stationary combustion sources such as compressors at pipeline installations as well as fugitive emissions along the length of the entire pipeline system. A natural gas transmission company that has several pipeline operations or networks within and across several provinces should use the provincial boundaries to identify its "pipeline transportation systems" and then report GHG emissions for each discrete system.
Q23 I have a facility that is a pipeline transportation system. What should I enter as the location of this facility?
The location of a pipeline transportation system can be defined as the location of the largest unit in the system. Alternatively, you could define the location of the facility as the point where the boundary coincides with the point of entry or start of the pipeline system. A description of the extent of the pipeline system and an indication of nearby cities or towns would also be helpful in locating such a facility. Once a location has been selected for the first year of reporting, it is important that it be kept constant in subsequent years (unless it no longer applies for some reason). Similarly, the explanations above apply to facilities other than pipeline transportation systems that are spread out over large areas.
Q24 What should be entered as the location of an offshore installation?
Offshore installations must be specified using longitudinal and latitudinal coordinates.
Q25 How does the presence on site of a cogeneration unit influence emissions reporting? What if I am not the operator of the cogeneration unit?
If there is a cogeneration unit located on site at your facility and it generates direct GHG emissions, these emissions are to be reported. The emissions are to be categorized under Stationary Fuel Combustion, since cogeneration units produce energy (typically of at least two forms). Total direct GHG emissions must be reported, even if some of the resultant energy is exported off site. If the operator of the cogeneration unit is different from the operator of the overall facility, a separate report must be submitted by the operator of the cogeneration unit (if the reporting threshold is reached).
Q26 Do emissions related to space heaters need to be reported?
Yes, reporters are required to include emissions from space heaters utilizing combustion (i.e. burning fuel), and these emissions are to be included as part of the total under the Stationary Fuel Combustion category (unless the fuel burned is a biomass material, in which case special consideration is necessary for the CO2 emissions - see Section 4.2.9).
Q27 Am I required to report emissions from the combustion of biomass?
Yes, it is necessary to calculate and report the quantity of emissions of CH4 and N2O from the combustion of biomass materials. This includes emissions resulting from biomass burned for any purpose except land clearing (see note below). The CO2 emissions from biomass combustion must be calculated and reported separately in the reporting tool. These CO2 emissions should not be included as part of the total emissions from the facility. However, the CH4 and N2O emissions are to be included in the emission totals. The following materials are considered to be biomass materials:
- plants or plant materials, animal waste, or any product made of either of these;
- wood and wood products, charcoal and agricultural residues and wastes (including organic matter such as trees, crops, grasses, tree litter or roots);
- that portion of biologically derived organic matter in municipal and industrial wastes (this would include wastewater treatment sludge from pulp and paper plants). It is important to note that only the biomass portion of industrial or municipal waste should be included in this category. If the portion derived from fossil fuels is combusted, the emissions from this portion must follow the rules for non-biomass based sources;
- black liquor;
- landfill gas;
- sludge gas; and
- animal- or plant-derived oils.
Note: Occasionally, tree stumps, branches, twigs and leaves are burned on site as land is cleared. The GHGs emitted (CO2, CH4 and N2O) from this activity should not be reported.
Q28 If most of the CO2 emissions from my facility are from the burning/combustion of natural gas in the boilers and furnaces, do they count as "CO2 emissions from the combustion of biomass"?
Standard commercial natural gas is a fossil fuel and hence does not fall into the category of biomass fuels. Thus, all GHG emissions from the combustion of commercial natural gas (e.g. CO2, CH4 and N2O) must be reported and counted in emission totals or when assessing whether a facility meets the reporting threshold.
Only specialized, biomass-derived gas (e.g. CH4 produced from a digester or landfill and usually used on site) would be considered a biomass fuel. (CO2 emissions from the combustion of biomass materials are not included in Stationary Fuel Combustion totals, as it is assumed that the biomass is produced in a sustainable manner).
Q29 How are emissions from electricity consumption reported by a facility?
Reporters are required to report on direct GHG emissions only from sources occurring at the facility. For electricity that may be generated on site, total GHG emissions resulting from the generation of this electricity should be reported even if some of the resultant electricity is exported off site. The indirect emissions associated with the import of electricity (not generated on site) should not be reported.
Q30 Where should CO2 emissions from natural gas sweetening be reported in terms of categorization?
CO2 released as a result of processing, such as the sweetening of natural gas, should be reported in the Venting Emissions category.
Q31 Do I need to report transportation emissions?
As stated in the Canada Gazette notice, on-site transportation emissions must be reported under their own category. Only emissions from machinery used for the on-site transportation of substances, materials or products used in the production process of the facility should be reported. As an example, the transport of feed materials (e.g. by truck or rail) from their on-site storage location to a specific process unit would be reported under this category. An example of a transportation activity that would not be reported would be a manager who uses a company vehicle (e.g. pickup truck or car) to conduct inspections of activities on the grounds of the facility. Additionally, emissions from transportation to and from the facility should not be reported.
Q32 How do I submit my GHG information to Environment Canada?
You can submit your facility's GHG information to Environment Canada's GHG Emissions Reporting Program (GHGRP) through Environment Canada's Single Window system. This system is an online mechanism for reporting information to Environment Canada under specific programs and to other agencies and jurisdictions, including:
- Environment Canada's National Pollutant Release Inventory (NPRI) program
- Alberta's Specified Gas Reporting Regulation (AB Reg. 251/2004)
- British Columbia's GHG Reporting Regulation (B.C. Reg. 272/2009)
- Ontario's GHG Reporting Regulation (O. Reg. 452/09)
Visit our website (www.ec.gc.ca/ges-ghg) to find a link to the reporting system and more information on how to access the system.
Publication and Confidentiality of Data
Q33 What is this facility-level data used for? Is it part of the data for Canada's National Greenhouse Gas Inventory that is submitted annually to the United Nations?
The facility data collected under the GHG Emissions Reporting Program (GHGRP) supports a number of objectives including providing Canadians with information on GHG emissions, supporting the development of the National GHG Inventory and for regulatory development purposes. The facility data informs the National GHG Inventory submission that Canada must prepare and submit annually to the United Nations under the United Nations Framework Convention on Climate Change.
Canada's National GHG Inventory is broader than industrial sources, as it includes all sources and sinks of GHGs caused by human activity. The inventory is largely based on emission estimates developed from national and provincial statistics. The facility data is used to compare and validate the national inventory estimates from industrial sources.
Q34 Will the information I provide to Environment Canada be kept confidential?
The information is being collected by Environment Canada, under the authority of the Canadian Environmental Protection Act, 1999 (CEPA 1999). The Minister of the Environment has indicated the intent to publish the GHG emission totals by gas and by facility (pursuant to the Canada Gazette notice). Persons will be afforded an opportunity to request that their information be treated as confidential and that it therefore not be published. If the Minister is of the view that the information for which a confidentiality request has been submitted is enveloped by one of the enumerated categories of information found in section 52 of CEPA 1999, then the Minister would be authorized to publish the information only pursuant to the public interest exemption found in subsection 53(3) of CEPA 1999. If the Minister questions the validity of a confidentiality request, procedures are set out in section 53 of CEPA 1999, affording persons an opportunity to further justify their claims with both the Minister and, failing that, the Federal Court. The information, once in the hands of Environment Canada, is subject to the provisions of the federal Privacy Act and the Access to Information Act.
Q35 Some industries might be concerned that releasing their GHG emissions data to the public could affect their competitive position. How have you addressed those concerns in the reporting system?
All facilities that exceed the threshold are required to report. Similar data are already being collected and disclosed by other governments, including the Government of Alberta. In addition, federal legislation provides companies with the opportunity to request the non-public disclosure of data whose publication they feel would jeopardize their competitive position, as defined under CEPA 1999. These provisions provide adequate protection of confidentiality where warranted, while at the same time ensuring public access to information that is in the public interest.
Q36 Who will have access to information reported?
The Minister of the Environment has indicated the intent to publish facility emissions data, i.e. emission totals by gas and by facility (except for confidential data protected under CEPA 1999). This information is published on Environment Canada's GHG website (www.ec.gc.ca/ges-ghg).
Provinces and territories can enter into a data-sharing agreement with Environment Canada to access the complete dataset if they meet specific requirements under CEPA 1999. In accordance with their respective provincial or territorial legislation, a copy of the reported data could be made publicly available, subject to terms of provincial or territorial privacy and access to information laws.
Q37 How do I request that my submission be treated as confidential?
There are provisions under CEPA 1999 whereby reporters may submit, with the information that they are required to provide, a written request that this information be treated as confidential based on reasons set out in CEPA 1999 (section 52).
During the online process of reporting emissions, reporters will be asked if they are requesting confidentiality of their report under CEPA 1999. A similar question will be asked if there are applicable provincial/territorial statutes. The reporter must choose yes or no; if yes is chosen, the reporter must submit a written request along with justification and supporting documentation to Environment Canada (and the provincial government, if applicable). The reporter should send this written request by mail, postmarked no later than the reporting deadline. Environment Canada will be alerted by the online reporting system that the request has been made, and the entire submission will be kept confidential until the request is processed.
Q38 If a reporter is granted confidentiality in the first reporting year, must that reporter submit a confidentiality request every year thereafter?
Yes, a request for confidentiality must be submitted each year, since a request for confidentiality applies only to the reporting year in which the request was made.
Q39 Is there an appeal process if a reporter has not been granted confidentiality? If so, what is the timeline to submit the appeal?
Under CEPA 1999, a reporter has the ability to submit an appeal. As per section 53 of CEPA 1999, when a request for confidentiality is denied by Environment Canada, the Department will inform the reporter that data submitted by the reporter will be published and that the reporter has the option of having this decision reviewed by the Federal Court within a 30-day period. If no appeal to the Federal Court is made, then the information is made publicly available. If an appeal is made, the Federal Court reviews the confidentiality request and the reporter's information is kept confidential until this process is complete.
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