Archived: Technical Guidance on Reporting Greenhouse Gas Emissions: appendix A

How many facilities are affected by mandatory GHG reporting? What sort of facilities are these?

Only those facilities that emit the equivalent of 50 kt or more of CO₂ eq units 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.

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.

Why did the GWP values change in 2013, and what does it mean for reporters?

Since 2013, the GWP values from the Intergovernmental Panel on Climate Change (IPCC) Fourth Assessment Report must be used by facilities to assess whether they meet the 50-kt CO₂ eq reporting threshold. The use of the latest GWP values is important to ensure that the facility-level GHG reporting occurring through the GHGRP aligns with the revised United Nations Framework Convention on Climate Change (UNFCCC) GHG reporting requirements and Canada’s National Greenhouse Gas Inventory. Canada’s National Greenhouse Gas Inventory Report (NIR), which is annually submitted to the UNFCCC, started using the updated GWP values in the 2015 submission for reporting 2013 emissions and removals. The use of the updated GWP values will also promote consistency with other GHG reporting initiatives (e.g. annual facility-level GHG reporting required by the United States Environmental Protection Agency).

The reporting threshold under Environment and Climate Change Canada’s GHGRP is 50kt or more of GHG emissions, in CO₂ eq 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 (for its Specified Gas Reporting Regulation), and British Columbia, Ontario, 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.  Particular attention should be given to the use of GWP values that may be required under provincial GHG reporting obligations, given that the GHGRP has incorporated the updated values, starting with the 2013 data year, and provinces may or may not use the updated GWPs.

Are landfills and incinerators included in the mandatory GHG reporting 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 4.2.7 for details.)

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 and Climate Change Canada’s Single Window System. The system is normally ready to collect data submissions by the spring of each year; therefore reporters are able to submit their information well in advance of the June 1st reporting deadline. Details regarding the online reporting tool are available on Environment and Climate Change Canada’s GHGRP website.

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 and Climate Change Canada.

Environment and Climate Change 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.

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 (see Enforcement and Compliance).

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

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

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.

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.

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

Environment and Climate Change Canada’s GHGRP website offers guidance on the reporting requirements and the online reporting tool.  Environment and Climate Change Canada has held GHG reporting information sessions in previous reporting cycles (e.g., webex), and communications will be sent out to facility contacts currently on the GHGRP’s distribution list if similar sessions are held from one reporting year to the next.

If you wish to be added to the GHGRP’s distribution list, you can send a request by email to ec.ges-ghg.ec@canada.ca.

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 many 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.

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.

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.

Since the Canada Gazette notice on GHG reporting requirements does not prescribe a 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:
   1. he or she has reviewed the submitted report and any supporting documents;
   2. he or she has exercised due diligence to ensure that the information provided is true and complete; and
   3. 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.

What are the requirements for the retention of records?

The Canada Gazette notices published under the federal GHG reporting program indicate that records must be maintained for a period of three years from the date the information must be submitted.

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 GHGRP, please contact:

Pollutant Inventories and Reporting Division
Environment and Climate Change Canada
Place Vincent Massey, 7^th Floor
351 St. Joseph Boulevard
Gatineau, QC K1A 0H3
Telephone: 819-938-3258 or toll-free at 1-877-877-8375
Email: ec.ges-ghg.ec@canada.ca

Provincial partners using the Single Window System for GHG reporting include Alberta, British Columbia and Ontario.

For assistance with Government of Alberta GHG reporting requirements, please contact the Alberta Environment and Parks' GHG Reporting Program at ESRD.GHG@gov.ab.ca, or the Alberta Environment and Parks' 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 GHGRegulator@gov.bc.ca.

For assistance with the Government of Ontario GHG reporting requirements, please contact the Ontario Ministry of Environment at GHGReporting@ontario.ca or at 416-649-4480 or 1-855-815-6400.

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, emission factors, and engineering estimates. Reporting facilities must use methods for estimating emissions that are consistent with the reporting guidelines adopted by the UNFCCC and developed by the IPCC (see Section 4.4).

Will any guidelines be issued on the estimation of GHG emissions for the reporting year?

There are no specific protocols for estimating GHG emissions that facilities must use at this time; however, reporting facilities must use methods that are consistent with the methodologies approved by the UNFCCC and developed by the IPCC. 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. Should any inconsistencies be found between this guide and the official Canada Gazette, Part I Notice with respect to reporting of greenhouse gases (GHGs) for 2015, the notice will prevail.

Help desk support is also available to facilities that may have questions on how to calculate their GHG emissions (see Q18).

If a reporting emitter adopts estimation or quantification protocols for future years that are different from those used in previous years, and if the resulting estimates of emissions differ significantly, how will the differing results be handled?

Development of a full domestic reporting system is an evolutionary process, which requires developing, testing, assessing and refining all aspects of reporting, including estimation and quantification protocols and methodologies. Until specific 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 notices published under the federal GHG reporting program, reporters must keep copies of the required information, together with any calculations, measurements and other data on which the information is based. For transparency, facilities should also identify in their GHG reports reasons behind emission changes from one year to the next, including methodological changes.

When reporting GHG emissions, is the requirement to report as a CO₂ eq or the actual tonnage of each gas? For example, would I report 100 tonnes of N₂O or 29 800 tonnes of CO₂ eq 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 or she needs to submit a report, he or she will need to convert the emissions to CO₂ eq units 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 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 this year, emissions for that facility must be reported.

Why does the pipeline definition refer to “pipeline transportation system,” while the definition used for other emissions-reporting purposes in the 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.

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.

Note: The requirement for latitude and longitude information is not mandatory for pipeline transportation systems, although this information can be provided along with other location details (in particular, if the reporter uses the location of the largest unit in the system to describe the location of the pipeline system).

Can you tell me more about the requirement for facilities to provide the latitude and longitude coordinates of the facility and how such information should be entered online for the report?

Since 2013, the Canada Gazette notice (requiring the reporting of GHG emissions from facilities for the specified year) has included the requirements that all facilities except pipeline transportation systems provide their latitude and longitude information. The majority of facilities already provide this information to Environment and Climate Change Canada as part of their NPRI reports during their first year of reporting. The latitude and longitude information will be used by Environment and Climate Change Canada to more precisely determine the location of the facilities and will enhance existing departmental public reporting on this facility-level GHG information (i.e., mapping of facilities). The reporter is to provide the latitude and longitude under the Geographical Address tab for the facility in the Single Window Information Manager of the Single Window System.

What should be entered as the location of an offshore installation?

Offshore installations must be specified using latitudinal and longitudinal coordinates.

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).

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).

Am I required to report emissions from the combustion of biomass?

Yes, it is necessary to calculate and report the quantity of emissions of methane (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;
• bio-alcohols;
• black liquor;
• landfill gas;
• sludge digestion 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.

Am I required to report CO₂ emissions from the fermentation of biomass materials?

No, reporters are not required to calculate and report CO₂ emissions from the fermentation of biomass materials. For example, in ethanol production, CO₂ emissions are generated from the fermentation of biomass materials (e.g., corn or wheat). These emissions are not to be reported to the GHGRP.

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 (i.e., are reported separately), as it is assumed that the biomass is produced in a sustainable manner.

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.

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.

Do I need to report transportation emissions?

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.

How do I submit my GHG information to Environment and Climate Change Canada?

You can submit your facility's GHG information to Environment and Climate Change Canada's GHGRP through Environment and Climate Change Canada's Single Window system. This system is an online mechanism for reporting information to Environment and Climate Change Canada under specific programs and to other agencies and jurisdictions, including:

• Environment and Climate Change Canada's 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 Greenhouse Gas Emissions Reporting Regulation (O. Reg. 452/09)

Visit our website to find a link to the reporting system and more information on how to access the system. 

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 GHGRP supports a number of objectives, including providing Canadians with information on GHG emissions, assisting with regulatory development, and supporting the development of the National Greenhouse Gas Inventory that Canada must prepare and submit annually to the United Nations under the UNFCCC.

Canada’s National Greenhouse Gas 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.

Will the information I provide to Environment and Climate Change Canada be kept confidential?

The information is being collected by Environment and Climate Change Canada, under the authority of CEPA 1999. The Minister of the Environment and Climate Change has indicated the intent to publish the GHG emission totals by gas and by facility (pursuant to the Canada Gazette notices published under the federal GHG reporting program).

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 and Climate Change Canada, is subject to the provisions of the federal Privacy Act and the Access to Information Act.

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 reporting threshold are required to report. Similar data are already being collected and disclosed by other governments, including the governments of Alberta, British Columbia, Ontario and Quebec. 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.

Who will have access to information reported?

The Minister of the Environment and Climate Change 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 and Climate Change Canada’s GHGRP website.

Provinces and territories can enter into a data-sharing agreement with Environment and Climate Change 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.

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 and Climate Change Canada (and the provincial government, if applicable). The reporter should attach this written request to the report prior to submitting it online.

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 to Environment and Climate Change Canada, since a request for confidentiality applies only to the reporting year in which the request was made.

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 and Climate Change 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.