Technical Guidance on Reporting Greenhouse Gas Emissions

Appendix A: Frequently Asked Questions

---

Appendix A: Frequently Asked Questions

Quick Reference

General

Q1 How many facilities will be affected by mandatory greenhouse gas (GHG) reporting? What sort of facilities are these?
Q2 What constitutes 50 kt of CO₂ eq?
Q3 The reporting threshold under Environment Canada's GHG Emissions Reporting Program (GHGRP) is 50 kilotonnes (kt) or more of GHG emissions, in CO₂ equivalent units. What are the reporting thresholds in other Canadian jurisdictions?
Q4 Are landfills and incinerators included in the mandatory GHG reporting requirements for emissions?
Q5 When can I submit the required information for this year's emissions? Can I send the information before June 1st?
Q6 Will the reported data be verified for accuracy?
Q7 Are there penalties for not reporting, late submission or faulty reporting?
Q8 Who must report emissions if the facility underwent a change of operator during the calendar year?
Q9 Do emissions need to be reported if a facility closed during the calendar year?
Q10 If the parent company of a facility is not Canadian, does the facility need to report?
Q11 Will you be offering any type of training sessions and/or workshops for GHG reporters?
Q12 What is the D-U-N-S number?
Q13 What is a Statement of Certification?
Q14 Who must sign the Statement of Certification on behalf of a reporting facility?
Q15 Since the Canada Gazette notice on reporting requirements does not indicate any specific mandatory protocol or methodology for estimation or quantification of GHG emissions, what is the need for a Statement of Certification by an officer of the reporting facility?
Q16 What are the requirements for the retention of records?
Q17 Will I receive any feedback on my report?

---

Technical Information

Q18 How are GHG emissions calculated by reporting facilities?
Q19 Will any guidelines be issued on the estimation of GHG emissions for the reporting year?
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?
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?
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"?
Q23 I have a facility that is a pipeline transportation system. What should I enter as the location of this facility?
Q24 What should be entered as the location of an offshore installation?
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?
Q26 Do emissions related to space heaters need to be reported?
Q27 Am I required to report emissions from the combustion of biomass?
Q28 If most of the CO₂emissions 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"?
Q29 How are emissions from electricity consumption reported by a facility?
Q30 Where should CO₂emissions from natural gas sweetening be reported in terms of categorization?
Q31 Do I need to report transportation emissions?

Q32 How do I submit my GHG information to Environment Canada?

---

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?
Q34 Will the information I provide to Environment Canada be kept confidential?
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?
Q36 Who will have access to information reported?
Q37 How do I request that my submission be treated as confidential?
Q38 If a reporter is granted confidentiality in the first reporting year, must that reporter submit a confidentiality request every year thereafter?
Q39 Is there an appeal process if a reporter has not been granted confidentiality? If so, what is the timeline to submit the appeal?

---

General

Q1 How many facilities will be affected by mandatory greenhouse gas (GHG) reporting? What sort of facilities are these?

Only those facilities that emit the equivalent of 50 000 tonnes (50 kt) or more of carbon dioxide (in CO₂ equivalent units, or CO₂ eq) per year are required to report. This threshold is expected to apply to over 500 facilities across Canada, in all sectors. Facilities that do not meet the reporting threshold are encouraged to report voluntarily.

Major industrial facilities that produce electricity, heat or steam on site using fossil fuels are those that would typically emit more than 50 kt of GHGs per year. These could include power generation facilities, integrated steel mills, facilities involved in smelting and refining metals, petroleum refineries, and chemical production facilities. Other operations, such as large landfills and incinerators, could also be subject to this mandatory reporting.

Q2 What constitutes 50 kt of CO₂ eq?

The following examples are given to provide context for the magnitude of this threshold. See Section 4 for further information regarding how to quantify your emissions.

• A commercial or institutional facility combusting natural gas for heat or process use in furnaces or boilers with a combined maximum heat input of 115 million kilojoules/hr (109 million BTU/hr), operating at full capacity, 24 hours per day, 7 days per week for one year would meet the threshold.
• The production of 17 159 tonnes of nitric acid in a “Type 1” dual-pressure plant with extended absorption would meet the threshold.
• The production of 32 051 tonnes of ammonia using the natural gas reforming process to produce hydrogen would meet the threshold.
• The combustion of 17.9 million litres of diesel fuel in one year in stationary sources such as diesel generators would meet the threshold.

Q3 The reporting threshold under Environment Canada's GHG Emissions Reporting Program (GHGRP) is 50 kilotonnes (kt) or more of GHG emissions, in CO₂ equivalent units. What are the reporting thresholds in other Canadian jurisdictions?

A number of provinces have GHG reporting programs, each specifying their own reporting requirements, including reporting thresholds. For example, the reporting threshold for Alberta is set at 50 kt, Ontario at 25 kt, and British Columbia, Quebec and Nova Scotia are at 10 kt. It is the facility's responsibility to understand the various GHG reporting obligations and to determine whether a GHG report is required to be submitted to the federal and/or provincial jurisdictions.

Q4 Are landfills and incinerators included in the mandatory GHGreporting requirements for emissions?

Any facility that emits more than 50 kt of CO₂ eq in the calendar year must report. Landfills and incinerators fall within the definition of "facility." (See the Waste category in Section 4.2.6 for details.)

Q5 When can I submit the required information for this year's emissions? Can I send the information before June 1st?

The information will be collected electronically through Environment Canada's Single Window system. The system is expected to be ready to collect data submissions by the spring. Reporters will therefore be able to access the reporting system early and submit their information well in advance of the June 1st reporting deadline. Details regarding the online reporting tool are available on Environment Canada's GHG website (www.ec.gc.ca/ges-ghg).

Q6 Will the reported data be verified for accuracy?

Facilities must ensure that the data they submit is accurate. Reporters are required to submit a Statement of Certification, signed by an authorized official, stating that the information contained in the attached emission report is true, accurate and complete.

Reporters also have a legal obligation to keep copies of the information submitted, along with any calculations, measurements and other data on which the information is based. All information must be kept for a period of three years from the date the information was reported to Environment Canada.

Environment Canada reviews the submitted information and conducts a number of checks for compliance purposes and for completeness. Clarifications may be sought from individual facilities where necessary.

Q7 Are there penalties for not reporting, late submission or faulty reporting?

All persons who operate a facility that is subject to the GHG reporting requirements outlined in the Canada Gazette notice under the authority of the Canadian Environmental Protection Act, 1999 (CEPA 1999) are legally obligated to provide whatever information is required by the notice. Any person in contravention of CEPA 1999 by failing to report, late submission or faulty reporting will be referred to enforcement staff and may be subject to enforcement action. Further information on enforcement and compliance under CEPA 1999 can be found online at: www.ec.gc.ca/lcpe-cepa (see Enforcement and Compliance).

Q8 Who must report emissions if the facility underwent a change of operator during the calendar year?

If the person who operates the facility that is subject to reporting changes during the calendar year, then the person who operates the facility as of December 31st, must report for the entire calendar year.

Q9 Do emissions need to be reported if a facility closed during the calendar year?

If operations at a facility are terminated in any calendar year, the last operator of that facility is required to report for the portion of the calendar year during which the facility was in operation (if the facility emissions meet the reporting threshold requirement). The last operator should inform the Pollutant Inventories and Reporting Division about the status of the facility to avoid further follow-up.

Q10 If the parent company of a facility is not Canadian, does the facility need to report?

If the facility is located in Canada and exceeds the reporting threshold, then the operator is required to submit a report for the facility. The operator would not, however, be required to provide parent company information if there is no Canadian parent company.

Q11 Will you be offering any type of training sessions and/or workshops for GHG reporters?

Environment Canada's GHG website (www.ec.gc.ca/ges-ghg) offers guidance on the reporting requirements and the online reporting tool.

Q12 What is the D-U-N-S number?

D-U-N-S numbers are unique nine-digit identification sequences that provide unique identifiers of single business entities while linking corporate family structures together. The internationally recognized numbering system is developed and maintained by the private firm of D&B (formerly Dun and Bradstreet).

D&B links the D-U-N-S numbers of parents, subsidiaries, headquarters and branches of more than 62 million corporate family members around the world. Used by the world's most influential standards-setting organizations, the D-U-N-S number is recognized, recommended and/or required by more than 50 global, industry and trade associations, including the United Nations, the U.S. federal government, the Australian government and the European Commission.

If a facility or company does not have a D-U-N-S number, it is not required to get one in order to submit an emissions report.

Q13 What is a Statement of Certification?

A Statement of Certification is a statement or confirmation signed by an authorized signing officer of the reporting company, indicating that the information submitted in response to the GHG reporting requirements is true, accurate and complete.

Q14 Who must sign the Statement of Certification on behalf of a reporting facility?

The reporting facility may designate anyone within its organization to sign, provided that the individual has delegated powers to accept legal responsibility for the information provided and is in a position to knowledgeably attest to the completeness and accuracy of the submitted report. Facilities may, for example, designate the chief executive officer, the environmental coordinator or the plant manager to certify the report. The authorized signing officer must certify the GHG emissions report electronically at the time of report submission through the online reporting tool.

Q15 Since the Canada Gazette notice on reporting requirements does not indicate any specific mandatory protocol or methodology for estimation or quantification of GHG emissions, what is the need for a Statement of Certification by an officer of the reporting facility?

There are two important reasons for the required certification:

1. To provide assurance, from a suitable representative of the reporting facility, that the facility has complied with the reporting requirements. In signing, the officer is attesting that:

• he/she has reviewed the submitted report and any supporting documents;
• he/she has exercised due diligence to ensure that the information provided is true and complete; and
• to the best of the signing officer's knowledge, the amounts and values provided in the report are accurate, based on reasonable estimates using available data and quantification methodology chosen by the reporting facility.

2. To provide a reasonable degree of openness, transparency and visible accountability in the reporting process and, in so doing, to ensure a high degree of public and stakeholder confidence in the integrity of the reporting system and the results obtained.

Q16 What are the requirements for the retention of records?

The Canada Gazette notice indicates that records must be maintained for a period of three years from the date the information must be submitted.

Q17 Will I receive any feedback on my report?

Individual feedback to reporters will not normally be provided (unless clarification is needed on specific information that was reported). However, appropriate government authorities will respond to specific requests for information.

---

For questions about the GHG Emissions Reporting Program, please contact:

Pollutant Inventories and Reporting Division
Environment Canada
200 Sacré-Coeur Boulevard, 8th Floor
Gatineau, QC K1A 0H3
Telephone: 819-994-0684 or Toll-free at 1-877-877-8375
Fax: 819-953-2347
Email: ges-ghg@ec.gc.ca

For assistance with Government of Alberta GHG reporting requirements, please contact the Alberta Environment GHG Program at aenv.ghg@gov.ab.ca, or the Alberta Environment Climate Change policy unit at 780-427-5200.

For assistance with the Government of British Columbia GHG reporting requirements, please contact the British Columbia Ministry of Environment at GHGReporting@gov.bc.ca or Dennis.Paradine@gov.bc.ca.

For assistance with the Government of Ontario GHG reporting requirements, please contact the Ontario Ministry of Environment at GHGReporting@ontario.ca.