Reporting greenhouse gas emissions: questions and answers

Understand the Greenhouse Gas Reporting Program and prepare your facility's emission report.

Use this page with our guide to determine whether you need to report, or when preparing your submission to the program.

This page is evolving. We will continue to add new questions and answers, as they are identified. Please contact us if you have additional questions that are not mentioned on this page, or if you need further clarification.

General information

The following questions address the Greenhouse Gas Reporting Program generally, introduce the expansion of the program, and link the program to those of other Canadian jurisdictions.

The federal Greenhouse Gas Reporting Program

1. What is the Greenhouse Gas Reporting Program?

The Greenhouse Gas Reporting Program (GHGRP) collects information from individual facilities relating to their annual greenhouse gas emissions. It was established in March 2004 by Environment and Climate Change Canada under the authority of section 46 of the Canadian Environmental Protection Act (CEPA).

The GHGRP is part of Canada’s ongoing effort to develop a harmonized and efficient mandatory greenhouse gas reporting system, in collaboration with the provinces and territories.

Key objectives of the program are:

  • to provide Canadians with consistent information on greenhouse gas emissions
  • to inform greenhouse gas emission estimates in the National Greenhouse Gas Inventory by industrial sectors
  • to support regulatory initiatives of the federal government

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2. For which greenhouse gases does the Greenhouse Gas Reporting Program track facility emissions?

The Greenhouse Gas Reporting Program tracks emissions from specific sources or activities occurring at the facility, for the following substances:

  • carbon dioxide (CO2)
  • methane (CH4)
  • nitrous oxide (N2O)
  • sulfur hexafluoride (SF6)
  • hydrofluorocarbons (HFCs)
  • perfluorocarbons (PFCs)

Both HFCs and PFCs are families of chemical compounds that include many individual gases.

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3. What is this facility-level data used for?

The facility data collected under the Greenhouse Gas Reporting Program supports a number of objectives, including:

  • providing Canadians with consistent tracking of information on greenhouse gas emissions from individual facilities
  • assisting with regulatory development
  • informing the National Greenhouse Gas Inventory submitted annually to the United Nations Framework Convention on Climate Change (UNFCCC)

Canada’s National Greenhouse Gas Inventory is a comprehensive inventory covering all sources and sinks of greenhouse gases caused by human activity in Canada. The facility data are comparable to the national inventory estimates by industrial sectors.

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4. Who can access this data?

Through the notice that is published annually, the Minister of the Environment indicates the intent to publish greenhouse gas emission totals by gas and by facility, except for confidential data that is protected under the Canadian Environmental Protection Act (CEPA). The public can access the latest data on the Canada.ca website and through Canada’s Open Data portal.

Provinces and territories can enter into a data-sharing agreement with the federal government to access the complete set of data collected if they meet specific requirements under CEPA. 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.

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5. Who must report under the federal Greenhouse Gas Reporting Program?

All facilities that emit 10 000 tonnes per year or more of greenhouse gases, in carbon dioxide equivalent units (CO2 eq), must submit a report for the calendar year identified in the notice published annually by the program.

Since 2017, all facilities engaged in carbon capture, transport and storage (CCTS) must submit a report covering their CCTS activities for the calendar year. They must do so regardless of their annual greenhouse gas emissions.

Facilities that do not meet the above conditions may nonetheless report their greenhouse gas emissions voluntarily to Environment and Climate Change Canada.

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6. What is considered a facility under the federal Greenhouse Gas Reporting Program?
Under what circumstances are multiple physical sites considered to be a single “integrated facility”?

The federal Greenhouse Gas Reporting Program defines a facility as: an integrated facility, a pipeline transportation system, or offshore installation.

An integrated facility includes all buildings, equipment, structures, on-site transportation machinery, and stationary items that are:

  • located on a single site, on multiple sites or between multiple sites
  • owned or operated by the same person(s); and
  • function as a single integrated site

In some cases, what may constitute an integrated facility can be complex. Therefore, reporters may inquire regarding their particular facility and the Department will consider these on a case-by-case basis.

Typically, several key criteria are considered. If sites are contiguous and owned or operated by the same company, they may be considered as an integrated facility. If sites are not contiguous, yet the multiple sites are dependent upon each other and they share the same activity type (determined by North American Industry Classification System (NAICS) code), they may also be considered as an integrated facility.

The following examples illustrate the distinction:

  • a power plant is one facility
  • a company operates several landfills that are not connected to each other and are at different locations. The landfills are considered to be separate facilities
  • a company operates a landfill at which greenhouse gases are captured and then used in a nearby power plant. If the power plant is owned or operated by the same company and is contiguous to the landfill, then the landfill and power plant are considered to be one integrated facility. Otherwise, the landfill and power plant are considered to be separate facilities
  • a company operates a mine that sends its concentrate streams to a smelter which is owned by the same company. If the smelter is not on a contiguous site, then the mine and smelter are considered to be separate facilities because they are engaged in different activities on separate non-contiguous sites.
7. How many facilities are affected by mandatory reporting under the federal Greenhouse Gas Reporting Program?

For the 2017 calendar year, 1 622 facilities reported their greenhouse gas emissions to Environment and Climate Change Canada.

Industrial facilities that produce electricity, heat or steam on site using fossil fuels would typically emit more than 10 000 tonnes in CO2 equivalent units of greenhouse gases 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.

Facilities that do not meet the reporting threshold are encouraged to report voluntarily.

8. What constitutes 10 000 tonnes in carbon dioxide equivalent units?

The following examples are given to provide context for the magnitude of this threshold.

A commercial or institutional facility combusting natural gas for heat would meet the threshold if it is described by both of the following:

  • it has a combined maximum heat input of 23.8 million kilojoules/hr (22.6 million BTU/hr)
  • it operates at full capacity, 24 hours per day, 7 days per week, for one year

The production of 50 000 tonnes of nitric acid, assuming an emission factor of 0.68 kg N2O per tonne nitric acid, would meet the threshold, solely based on industrial process emissions.

The production of ammonia or hydrogen using approximately 2.5 million m3 of natural gas feedstock is likely to meet the threshold, solely based on industrial process emissions.

The combustion of 3.8 million litres of diesel fuel in one year in stationary sources such as diesel generators would meet the threshold.

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9. Are there penalties for not reporting, late submission, or faulty reporting of information under the federal Greenhouse Gas Reporting Program?

All persons who operate a facility that is subject to the reporting requirements outlined in the annual notice for greenhouse gas reporting must provide whatever information is required by this notice. Anyone who fails to report, does not meet the submission deadline, or reports faulty information may be contravening the Canadian Environmental Protection Act (CEPA) and will be referred to enforcement staff, which may lead to enforcement action.

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10. Does Environment and Climate Change Canada review submitted information?
Must reporters obtain verification of their information by third parties?

Reporters must ensure that the data are accurate when they submit. We review the submitted information and conduct a number of checks for completeness, for compliance with the requirements, and to identify potential errors (for example, significant and unexplained changes in emissions). We may seek clarification from individual facilities where necessary.

Reporters do not have to obtain third-party verification of their submissions. Nevertheless, the information reported for a facility should be verifiable, which means that the reporter must retain any information that would allow the government or a third party to verify the submitted information.

Along with the facility emission report, reporters must also submit a Statement of Certification. It indicates that the information submitted in response to the greenhouse gas reporting requirements is true, accurate, and complete.

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11. Does Environment and Climate Change Canada accept voluntarily submitted greenhouse gas emission reports?

Yes, facilities with annual emissions falling below the reporting threshold may voluntarily report their greenhouse gas emissions, and those emissions are included in the published dataset. Voluntary submissions should still meet the reporting requirements as specified in the notices issued under the federal Greenhouse Gas Reporting Program.

Expansion of the federal Greenhouse Gas Reporting Program

12. What is the expansion of the federal Greenhouse Gas Reporting Program?

In 2016, Environment and Climate Change Canada proposed changes to expand the annual reporting requirements issued under the Greenhouse Gas Reporting Program. These changes are being implemented in a phased approach. For Phase 1 of the GHGRP expansion, the notice requiring the reporting of 2017 greenhouse gas (GHG) information, published in December 2017, included the changes introduced in this phase. The reporting threshold was lowered to require all facilities emitting 10 kilotonnes or more of GHGs (in carbon dioxide equivalent units) to report. Specific industry sectors were also required to report additional information, using prescribed methods to determine their emissions.

As part of Phase 2 of the GHGRP expansion, the notice requiring the reporting of 2018 GHG information, published in January 2019, included expanded reporting requirements and the use of specific methods for additional sectors/activities.

13. All other facilities with annual emissions above 10 000 tonnes are subject to the basic emission reporting requirements. They must report their greenhouse gas emissions by specific categories or sources of emissions. Is the expansion of the Greenhouse Gas Reporting Program retroactive to previous years?

Phase 1 of the GHGRP expansion started in 2017, and as part of this phase, facilities engaged in carbon capture, transport and storage (CCTS), regardless of their annual greenhouse gas emissions, were required to submit a report covering their CCTS activities for 2017 and for relevant years for the period 2014 to 2016.

Since the 2018 calendar year, CCTS facilities that already submitted a report for 2014 to 2017 are only required to submit a report covering their CCTS activities in the specific year in which they are reporting.

For all other facilities, the new reporting threshold and reporting requirements do not apply to calendar years prior to 2017.

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Other reporting programs

14. The reporting threshold for the federal Greenhouse Gas Reporting Program is 10 000 tonnes in CO2 equivalent units. What are the reporting thresholds for reporting programs in other Canadian jurisdictions?

A number of provinces have regulations that require facilities to monitor and report information on their greenhouse gas emissions, each specifying their own reporting requirements, including reporting thresholds. This includes the provincial governments of Alberta, British Columbia, New Brunswick, Newfoundland and Labrador, Nova Scotia, Ontario, Quebec, and Saskatchewan. Most of the provincial reporting thresholds match the federal reporting threshold of 10 000 tonnes. However, these are all governed by their respective provincial regulations which may change over time.

It is the facility’s responsibility to understand the various greenhouse gas reporting obligations and to determine whether a greenhouse gas emission report is required to be submitted to the federal and/or provincial jurisdictions. Particular attention should be given to the use of Global Warming Potential (GWP) values that may be required under provincial greenhouse gas reporting obligations in the event they differ from the GWP values used in federal reporting.

15. Why is it necessary for the federal government to collect the same or similar data that are already provided to provincial and territorial governments?

The federal Greenhouse Gas Reporting Program was expanded to meet several objectives. A primary objective is to better integrate the collected facility-level data into the national greenhouse gas inventory, which is submitted to the United Nations Framework Convention on Climate Change (UNFCCC). In some instances, international guidelines specify methods and data requirements over and above what is required by the reporting obligations of provinces and territories.

Furthermore, Environment and Climate Change Canada does not currently have access to the data that facilities are reporting to provincial governments, other than published aggregated totals. While the federal Single Window system provides data collection services for several provinces, the collected data are transferred directly to the respective provinces and cannot be used by the federal jurisdiction.

16. My province or territory requires me to submit a greenhouse gas emission report for my facility. Does the federal Greenhouse Gas Reporting Program accept submissions of provincial reports to meet the expanded federal reporting requirements?

For the 2019 calendar year, Environment and Climate Change Canada will continue to allow facilities subject to the expanded reporting requirements issued under phases 1 and 2 of the Greenhouse Gas Reporting Program expansion to attach their provincial reports to their federal submission. This is a provisional option and is available only to those facilities who are already reporting the same or similar data to provincial programs in British Columbia, Quebec, Nova Scotia and Newfoundland and Labrador.

Facilities in these provinces are provided with this option because the information they report to the provincial governments aligns closely enough to the federal Greenhouse Gas Reporting Program’s expanded requirements to warrant examining whether or not the reports can be adapted to the program.

Note that facilities choosing this option must do so in the ECCC reporting application in the Single Window system. A federal GHG report, which may include a provincial report as an attachment, is required. The provincial report attachment/upload is used to fulfill expanded reporting requirements only. General emissions data (i.e. emissions by source category) are still required to be reported in the federal report (in Sections A, B and C).

17. Can my GHGRP report submission be used to fulfill my provincial GHG reporting obligations or vice versa?

Within the ECCC GHG application in the Single Window system, a single report can fulfill both federal and provincial reporting requirements when there is a GHG report type option that includes ‘ECCC & your province’. For example, there are ECCC & AB, ECCC & SK, ECCC & NB, ECCC & NS, and ECCC & ON report type options available for facilities in these respective provinces. When this type of reporting option is selected, it means that the facility can submit a single report to both the federal GHGRP and the provincial GHG reporting program. If this report type is either not available or not selected, a report must be submitted to ECCC separately from any report that is submitted to your province/territory. In this case, the report type to select is ECCC only.

A submission to your province only would never constitute a submission to the federal GHGRP.

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18. Starting in 2020, my facility is required to report under the federal Output Based Pricing System (OBPS) Regulations. Is this the same as a GHGRP report?

No. The OBPS report is separate from the GHGRP report, although certain emission data are required by both initiatives. A GHGRP report submission is always required if the facility meets the GHGRP reporting criteria. There are also reporting requirements that are unique to each reporting obligation, reflecting the different objectives and scope of the GHGRP and the OBPS.

ECCC has made efforts to align and integrate GHGRP and OBPS reporting where possible and will continue this work to streamline reporting over time. In the meantime, for reporting of 2019 data, you will need to submit separate reports.

To reduce burden on reporters while alignment and integration efforts continue, the GHGRP is allowing facilities that are also subject to the federal OBPS reporting to use the methods required by the OBPS to calculate emissions for GHGRP reporting. Further, the OBPS reporting application will include an OBPS to GHGRP printout which will guide reporters on how to map similar reporting parameters from the OBPS to the GHGRP report.

Reporters must keep in mind that differences exist in the GHGRP and OBPS reporting requirements that may require different values to be reported to each program (e.g., under the GHGRP, there is no exemption for upstream oil & gas methane venting and leakage emissions). The differences are highlighted in the OBPS to GHGRP printout.

Reporters subject to GHGRP expanded reporting requirements are required to enter data in the activity reporting screens in the GHGRP report. Following completion of these activity reporting screens, a reporter can choose the option to automatically populate the emission totals (by source category and by gas) found in Sections A, B and C of the report. This reduces the time to complete the GHGRP report, and eliminates the need for any mapping between the GHGRP and OBPS reports.

19. My facility is subject to mandatory reporting under both the federal GHGRP and Alberta’s Specified Gas Reporting Regulation. Each of these programs prescribes methodologies for emissions calculations. Are these methods the same? How can I ensure my facility is in compliance with both programs?

ECCC has worked with the Government of Alberta to align GHG emission quantification methodologies where possible, and will continue these efforts as new or updated methods are added. A number of methodologies in both the federal and provincial guidance documents are consistent.

To clarify this, ECCC has identified in the 2019 GHGRP notice and quantification documents the Alberta-specific methodologies that are considered consistent with GHGRP methods and that may be used to report federally and to Alberta. These methods also appear in the shared Single Window reporting application used to submit a combined report to ECCC and Alberta. Where significant differences in methodologies are noted, we encourage you to inform our program. Where significant differences in methodologies are noted, we encourage you to inform our program.

Administrative

The following questions address administrative aspects of reporting, including reporting timelines and required information about companies and facilities.

Reporting process and timelines

20. How do I submit my facility’s information to the federal Greenhouse Gas Reporting Program?

You can submit your facility's greenhouse gas information to the federal Greenhouse Gas Reporting Program through the federal Single Window (SW) system. The SW system is an online mechanism for reporting information under specific federal programs and to other agencies and jurisdictions, including:

Within the SW system, the Single Window Information Manager (SWIM) module allows you to enter/edit/update information about your profile, organizations, facilities, and contacts. It is your entry-point into several programs’ reporting modules.

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21. By when do I submit my facility’s 2019 information to the federal Greenhouse Gas Reporting Program? Can I submit the information before this deadline?

The deadline for submitting your 2019 report is June 1st, 2020.

The Single Window system is normally ready to collect submissions by March of each year, so you will be able to submit your report well in advance of the June 1st deadline.

22. For how long must records associated with my greenhouse gas emission report be retained?

Records associated with your report submitted to the federal Greenhouse Gas Reporting Program must be kept for a period of three years from the submission deadline. For example, your report for the 2019 calendar year must be submitted by June 1st 2020, so any records that are associated with your report must be kept until June 1st, 2023.

23. Will you be offering any type of training sessions or workshops for reporters?

Guidance is available on the reporting requirements and the online reporting tool. As in previous reporting cycles, information sessions will be held on greenhouse gas reporting. Communications will be sent out to facility contacts currently on our distribution list whenever new material is available.

Requests to be added to the distribution list can be sent by email to ec.ges-ghg.ec@canada.ca.

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24. Will I receive any feedback on my greenhouse gas emission 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.

Provincial partners using the Single Window System for greenhouse gas reporting include Alberta, British Columbia, Ontario, New Brunswick, Nova Scotia and Saskatchewan. If you have specific questions about your report that are not mentioned in this document, please see the Contact us section.

Reporting companies

25. My parent company is not Canadian. Do I still have to report for my facility?

Yes, the greenhouse gas reporting requirements apply to all facilities located in Canada, regardless of the nationality of the parent company. However, you would not be required to provide information on the foreign parent company in your report.

26. What is the D-U-N-S number of a company?

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 your facility or company does not have a D-U-N-S number, then you are not required to get one in order to submit a greenhouse gas emission report to us.

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27. My facility closed during the calendar year. Do I still need to report for it?

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 federal Greenhouse Gas Reporting Program about the status of the facility to avoid further follow-up.

28. Who must report for a facility if it underwent a change of operator during the calendar year?

The person operating the facility as of December 31st of the calendar year must report the facility’s greenhouse gas emissions for the entire calendar year (not just the period during which the person operated the facility).

Facility information

29. What is the North American Industry Classification System (NAICS)?

NAICS is an industry classification system developed by Canada, Mexico, and the United States to provide common definitions for the three countries’ industries. Your facility’s primary economic activity has a corresponding six-digit code under NAICS, which you must include in your report.

Facilities are required to provide the NAICS code that describes the primary activity occurring at the facility. We also use NAICS to help clarify which industries are subject to the additional reporting and quantification requirements that we have introduced under the expanded federal Greenhouse Gas Reporting Program.

In 2017, Statistics Canada updated the list of industries under NAICS, and the Single Window system was also updated to use the NAICS 2017 information for facilities. If you are an existing reporter, the NAICS code that you used in previous years to describe your facility may have changed.

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30. Do I need to report the latitude and longitude coordinates of my facility?
How do I enter this information into the report?

You must report the latitude and longitude coordinates of your facility, unless it is a pipeline transportation system. To provide your facility’s latitude and longitude coordinates, log into the Single Window reporting system and go to the Geographical Address tab for the facility in the Single Window Information Manager (SWIM) module.

The majority of facilities already provide this information to Environment and Climate Change Canada as part of their National Pollutant Release Inventory (NPRI) reports during their first year of reporting. The latitude and longitude information is used to more precisely determine facility locations. It also enhances existing departmental public reporting of facility-level greenhouse gas information (for example, mapping facilities).

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31. My facility is a pipeline transportation system. What do I report as its latitude and longitude coordinates?

You are not required to provide latitude and longitude coordinates for your pipeline transportation system. However, you can provide the following information to help pinpoint the location of your facility for us:

  • the location of the largest unit in the pipeline transportation system
  • the starting and end points of the pipeline transportation system
  • a description of the extent of the pipeline system and an indication of nearby cities or towns

Once a location has been selected for the first year of reporting, it is important that it be kept constant for subsequent years (unless it no longer applies).

32. My facility is an offshore installation. What do I report for its location?

You must specify your offshore installation’s location in terms of its latitude and longitude coordinates.

Statement of Certification

33. What is a Statement of Certification, and why is it required to be submitted with the report?

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

The Statement of Certification confirms that the reporting company has complied with the reporting requirements for the facility, because a suitable representative of the company attests to all of the following:

  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
  3. to the best of the representative’s knowledge, the amounts and values provided in the report are accurate, based on reasonable estimates using available data and appropriate quantification methodology

The Statement of Certification improves the openness, transparency and accountability in the reporting process. This ensures a high degree of public and stakeholder confidence in the integrity of the reporting system and in the results obtained.

34. Who must sign the Statement of Certification on behalf of a company reporting for a facility?

The reporting company may designate anyone within its organization to sign the statement, if the designated person meets both of the following:

  • he or she has delegated authority to accept legal responsibility for the information provided
  • he or she is in a position to knowledgeably attest to the completeness and accuracy of the report for the facility

For example, reporting companies may designate the chief executive officer, the chief environmental officer or the plant manager to certify the report.

The authorized signing officer must electronically certify the greenhouse gas emission report at the time of submission via the online reporting system.

Confidentiality procedures

35. I am concerned that releasing my facility’s greenhouse gas emission data to the public could affect my company’s competitive position. How have you addressed these concerns in the federal Greenhouse Gas Reporting Program?

All facilities that meet the reporting criteria under the federal Greenhouse Gas Reporting Program must report their emissions. Similar data are already being collected and made publicly available by provincial governments, including Alberta, British Columbia, Ontario and Quebec.

However, the emissions are published in an aggregated format, grouping them by facility and greenhouse gas. Furthermore, the federal program has confidentiality procedures in place, which allow reporters to request that portions of the submitted information be kept confidential.

36. To what extent would the information that I provide to you be kept confidential?

The information is being collected by Environment and Climate Change Canada, under the authority of the Canadian Environmental Protection Act (CEPA). Through the annually published notice, the Minister of the Environment indicates the intent to publish the greenhouse gas emission totals by gas and by facility, except for confidential data that is protected under CEPA.

Reporters will be afforded an opportunity to request that the provided information be treated as confidential and that it therefore not be published. If the Minister determines that at least one of the reasons listed in section 52 of CEPA applies to the information for which your confidentiality request has been submitted, then the Minister would only be authorized to publish the information under the public interest exemption found in subsection 53(3) of CEPA.

If the Minister questions the validity of a confidentiality request, procedures are set out in section 53 of CEPA that allow you to further justify the claims to the Minister and, failing that, to the Federal Court. Once the information is in the custody of Environment and Climate Change Canada, it is subject to the provisions of the federal Privacy Act and the federal Access to Information Act.

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37. Is confidentiality handled differently under the expansion of the federal Greenhouse Gas Reporting Program?

No, the confidentiality procedures remain the same under the expansion of the federal Greenhouse Gas Reporting Program.

Emission totals will be published by gas and by facility. Integration of the facility data into Canada’s National Inventory Report will be done in a way that maintains the confidentiality of the data, where required. In this way, there will be no change in the level of data published as a result of the program expansion.

38. How do I request that my submission to you under the federal Greenhouse Gas Reporting Program be treated as confidential?

The Canadian Environmental Protection Act (CEPA) contains provisions for confidentiality. Under these provisions, a reporter may submit, along with the report, a written request that the provided information be treated as confidential. The request must be based on one or more of the reasons set out in section 52 of CEPA.

During the online reporting process, you will be asked if you are requesting confidentiality for your report under CEPA. A similar question will be asked if there are applicable provincial statutes. If you indicate that you are requesting confidentiality, then you must submit a written request along with justification and supporting documentation to Environment and Climate Change Canada (and the provincial or territorial government, if applicable).

Upload the written request to your online report before submitting the report.

39. I am granted confidentiality in the first reporting year for my facility. Do I have to submit a confidentiality request in each subsequent year?

A request for confidentiality applies only to the individual report to which it is attached. If such a request is granted, then confidentiality will apply to its associated report. However, confidentiality will not be automatically applied to reports for subsequent calendar years. This means that you must submit a separate request with each report that you want to be treated as confidential.

40. If I am not granted confidentiality for my submitted data, is there an appeal process? What is the timeline to submit the appeal?

Under the Canadian Environmental Protection Act (CEPA), you can submit an appeal to the Federal Court to reverse the decision. Per section 53 of CEPA, if your request for confidentiality is denied, Environment and Climate Change Canada will inform you that your submitted data will be published and that you have the option to have the Federal Court review the decision within a 30-day period.

If you do not appeal the decision to the Federal Court, then your information will be published. If you do appeal, your information will be kept confidential while the Federal Court reviews the decision not to grant your confidentiality request.

General requirements

The requirements discussed in the following questions are potentially applicable to all facilities reporting to the federal Greenhouse Gas Reporting Program.

General reporting requirements

41. How do I convert the actual tonnage of my facility’s emissions of each greenhouse gas to the facility’s total emissions in CO2 equivalent units (CO2 eq)?

The CO2 equivalent of a facility’s greenhouse gas emissions is interpreted as the amount of CO2 emissions that would be required to produce a global warming effect similar to that caused by your facility’s actual greenhouse gas emissions.

To convert your facility’s emissions to CO2 equivalent units, multiply the amount of each greenhouse gas (in tonnes of that gas) by its associated global warming potential (GWP). Your facility’s total emissions in CO2 equivalent units are equal to the sum of those converted amounts.

42. Which global warming potential values do I use to convert my facility’s emissions to CO2 equivalent units?

You must use the Global Warming Potential (GWP) values that we have published in our 2019 Notice. These values are the same as those published in the Fourth Assessment Report of the Intergovernmental Panel on Climate Change (IPCC), and we have used them since the 2013 calendar year.

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43. Do I report my facility’s emissions in CO2 equivalent units or as the actual tonnage of each greenhouse gas? For example, would I report 100 tonnes of N2O or 29 800 tonnes in CO2 equivalent units of N2O?

You are required to report the emissions of each individual greenhouse gas expressed in its actual tonnage. For the example given in the question, you would report 100 tonnes of N2O.

When assessing whether you must report, convert your facility’s total emissions to CO2 equivalent units, in order to compare against the reporting threshold.

44. Is there a ‘de minimis’ exemption from reporting greenhouse gas emissions from sources that account for less than a certain percentage of total facility emissions?

There is no overall ‘de minimis’ exemption from reporting greenhouse gas emissions from sources that only represent a small proportion of total facility emissions.
However, under the expanded quantification requirements, there are several ‘de minimis’ exemptions within the sections related to fuel combustion, iron and steel production, and base metal production.

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45. What is the relationship between the fugitive, flaring, venting, and leakage source categories?

‘Flaring’, ‘venting’, and ‘leakage’ are individual source categories that are grouped together under the label ‘fugitive’ (that is, fugitive = flaring + venting + leakage). Venting and flaring emissions result from controlled release of gases, while leakage emissions come from accidental releases and leaks.

Before the 2017 calendar year, the ‘leakage’ emissions source category was called ‘fugitive’ emissions by the program, and the ‘fugitive’ group of source categories was not used. We have changed to the current source category labels to align with those of the National Greenhouse Gas Inventory.

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46. Why are emissions from hydrogen production (steam methane reforming) categorized differently depending on the sector?

Hydrogen production emissions are categorized as either industrial process or fugitive (venting) emissions, depending on the sector in which the production occurs. In sectors producing fossil fuels (e.g., petroleum refineries, bitumen upgrading), these emissions are allocated to the venting emissions category, while in other industrial sectors, these emissions are allocated to the industrial process emissions category. While it is recognized that these emissions are produced from the same process, the difference in allocation is to maintain alignment with national inventory reporting requirements in accordance with the Intergovernmental Panel on Climate Change (IPCC) guidance related to international reporting of GHGs. Aside from the difference in allocation, there is no difference in the treatment of these emissions.

47. Do I report emissions from the combustion of biomass materials in my facility?

Yes, you must report emissions of CO2, CH4, and N2O from biomass combustion, but do not include these CO2 emissions when calculating your facility’s total emissions (do include the CH4 and N2O emissions in the total). Emissions of CO2 from biomass combustion must be reported separately from the facility’s total.

Biomass combustion includes biomass materials burned for any purpose except land clearing. The following materials are all considered to be biomass materials:

  • plants or plant materials, animal waste, or any product made of either of these, including wood and wood products, charcoal and agricultural residues
  • biologically derived organic matter in municipal and industrial wastes
  • landfill gas, bio-alcohols, black liquor, sludge digestion gas, animal-derived oils, and plant-derived oils

Occasionally, tree stumps, branches, twigs and leaves are burned on site as land is cleared. You are not required to report the greenhouse gas emissions from this activity.

48. Do I report emissions from the decomposition of biomass materials in my facility?

You must report emissions of CH4 or N2O that result from the decomposition of biomass materials in your facility. However, you are not required to report the CO2 emissions that result from the decomposition of biomass materials.

These emissions should be reported under the Wastewater source category if the decomposition occurs in a wastewater treatment process. If the decomposition occurs in a waste disposal process, report the emissions under the Waste source category.

49. Do I report emissions from the fermentation of biomass materials in my facility?

No, you are not required to include CO2 emissions from the fermentation of biomass materials in your facility’s greenhouse emissions.

For example, you are not required to report the CO2 emissions that result from the fermentation of sugar or converted starch (contained in grains such as corn and wheat) in an ethanol production process that would occur in your facility.

50. Are facilities from the agriculture sector required to report their greenhouse gas emissions under the federal Greenhouse Gas Reporting Program?
What sources of emissions are covered?

The GHG reporting requirements issued by Environment and Climate Change Canada under its GHG Reporting Program apply to any facility with annual GHG emissions exceeding 10 kilotonnes (in CO2 equivalent).

For the agriculture sector, the sources of emissions covered by these reporting requirements that would apply to facilities in this sector include fuels burned on-site at the facility in stationary combustion sources (e.g. to heat buildings, barns) and in transportation machinery or equipment (e.g. farming equipment, vehicles not licensed for public roads). The following sources are not covered:

  • emissions from enteric fermentation
  • manure management
  • agricultural soils
  • crop residue burning
  • application of fertilizers

It is not anticipated that any facilities in the agriculture sector (e.g. farming operations, feedlots) would trigger the 10-kt threshold due to emissions from on-site fuel use.

51. Is natural gas considered to be a biomass fuel under the federal Greenhouse Gas Reporting Program?

Standard commercial natural gas is a fossil fuel, so it does not fall into the category of biomass fuels. Therefore, you must report all greenhouse gas emissions from the combustion of commercial natural gas and include them in the facility’s total.

52. Are landfills, incinerators and wastewater treatment plants covered by the reporting requirements?

Yes, these types of operations fall within our definition of “facility”. You must report for all landfills, incinerators or wastewater treatment plants that annually emit more than 10 000 tonnes in carbon dioxide equivalent units, or that are part of a facility that emits more than 10 000 tonnes in carbon dioxide equivalent units.

Note that these facilities should pay special attention to what constitutes biomass or non-biomass CO2 emissions. For example, flaring of landfill gas or gas derived from wastewater treatment, assuming these are bio-derived sources, should be categorized as waste or wastewater emissions (CH4 and N2O) but the biomass CO2 emissions are simply categorized as CO2 from biomass combustion. CO2 from biomass combustion is not added to the facility total.

53. Do I report emissions from transportation?

You must report emissions from on-site transportation activities that occur in your facility, under the “On-site Transportation” source category of emissions. This category includes the releases from fuel combustion in machinery that is used for transport or movement of the substances, materials, equipment or products that are used in the production process at your facility. It also includes releases from vehicles that are not licensed for use on public roads.

For example, you must report the transport of feed materials (for example, by truck or rail) from their on-site storage location to a specific process unit. On the other hand, you are not required to report a manager’s use of a company vehicle to conduct inspection of activities on the grounds of the facility. Similarly, you are not required to report emissions from transportation to or from the facility (e.g. the delivery of material).

54. Do I report emissions from space heaters?

You must report emissions from space heaters that burn fuel in your facility, under the “Stationary Fuel Combustion” source category of emissions.

If the space heaters are burning non-biomass fuels, then their emissions must be included in the facility’s total emissions. If the space heaters burn biomass fuel, then their CO2 emissions must be reported separately.

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55. How does the presence on site of a cogeneration unit influence emission 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 greenhouse gas emissions, these emissions are to be reported. The emissions are to be categorized under Stationary Fuel Combustion. The total greenhouse gas emissions that are generated by the cogeneration unit 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).

56. Why does the federal Greenhouse Gas Reporting Program’s pipeline definition refer to a “pipeline transportation system”, while the definition used by the National Pollutant Release Inventory (NPRI) refers to a “pipeline installation”?

A pipeline is considered a mode of transport in the federal Greenhouse Gas Reporting Program. For reporting purposes, sources of emissions include both:

  • point-source emissions associated with stationary combustion (for example, compressors at pipeline installations)
  • fugitive emissions along the entire length of the pipeline system (for example, a pipeline transporting natural gas or CO2)

A natural gas transmission company that has several pipeline operations, or networks within and across several provinces, must:

  1. use the provincial boundaries to identify its “pipeline transportation systems”
  2. report greenhouse gas emissions for each of these discrete systems
57. How do I report emissions from electricity consumption?

You are not required to report the indirect emissions associated with electricity that was not generated in your facility. For electricity that is generated in your facility, you must report all of the greenhouse gas emissions that result from electricity generation, even if some of the electricity is not used by your facility (for example, sold to the grid).

58. Under what source category do I report CO2 emissions from the sweetening of natural gas?

You must report the CO2 emissions resulting from natural gas processing, such as sweetening, under the Venting source category of emissions.

General quantification requirements

59. How do I calculate the greenhouse gas emissions for my facility?

If your facility is in the sectors that we identified for the expansion of the federal Greenhouse Gas Reporting Program, you must use the methods defined in “Canada’s Greenhouse Gas Quantification Requirements.”

Otherwise, you must use methods that are consistent with the guidelines that the Intergovernmental Panel on Climate Change (IPCC) published in 2006. For each emissions value that you report to us, you must indicate whether you have determined it using monitoring or direct measurement, mass balance, emission factors, or engineering estimates. Alternatively, you can use the methods provided in the above noted quantification requirements document that are applicable to the emission sources of your facility’s operation.

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60. Will any guidelines be available to me on the calculation of greenhouse gas emissions for this reporting year?

The technical guidance document issued by the Greenhouse Gas Reporting Program will help you determine if you are required to submit a report this year; it also includes technical information on the reporting process and on available methods that meet the requirements. The guidance is typically updated shortly after the annual notice is published to reflect the changes to the reporting and quantification requirements for the relevant calendar year. For facilities that are subject to the expanded federal Greenhouse Gas Reporting Program requirements, our quantification requirements document describes the methods that you must use.

For facilities that are subject to the expanded federal Greenhouse Gas Reporting Program requirements, our quantification requirements document describes the methods that you must use.

For other facilities, we do not require you to follow any specific protocols for calculating greenhouse gas emissions. However, the methods that you do use must be consistent with the methodologies that the Intergovernmental Panel on Climate Change (IPCC) published in 2006. For emissions from fuel combustion, you can also use the methods described in Chapter 2 of our quantification requirements document.

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61. What is a good source for emission factors to use in the calculation of my facility’s emissions?

“Canada’s Greenhouse Gas Quantification Requirements” contains methods to quantify emissions from certain activities and sectors. These methods must be used by facilities subject to the expanded requirements.

Some of the methods provide tables of default emission factors. Non-expansion facilities can use these emission factors, if they wish. Alternatively, they may consult the latest greenhouse gas inventory report for Canada, which also provides up-to-date emission factors (see Part II of the report).

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62. If the quantification methods that I will use in future years are different from those that I am using in this year, or have used in previous years, how will the differing results be handled (if they are significantly different)?

Currently, specified quantification methods are available for calculating emissions from fuel combustion (including stationary fuel combustion, on site transportation and flaring); carbon capture, transport and storage (CCTS); and certain industrial processes that occur in identified industry sectors that are subject to the expanded reporting requirements. Quantification methods for other sectors or emission sources will require further testing, assessment, and refinement. For this reason, we expect there to be variations in results as the selected methodologies change from one year to the next.

To mitigate the effects of these variations, reporters are required to keep records of all the submitted information, and the measurements, calculations, and other data upon which it is based. Furthermore, for transparency, reports should provide the reasons why emissions in your facility have changed from one year to the next, including the changes in methods that you have made.

Expanded requirements

The information presented in the following questions only apply to specific sectors of the Canadian economy (see question 63).

Expanded reporting requirements

63. Do the expanded reporting and quantification requirements apply to me?

To determine if your facility is subject to the expanded reporting requirements, you should first determine if your facility reports under any of the NAICS codes listed in Table 2 of Schedule 3 of the 2019 GHGRP Notice (also listed below). If yes, you should then determine if the facility undertakes any of the activities listed under paragraph 1(b) of Schedule 3 (also listed below). If both are true, then the facility is subject to expanded reporting requirements. In addition, despite the NAICS code, if the facility is engaged in CO2 capture, transport, injection and storage activities, it is subject to expanded reporting requirements. The majority of activities listed have a corresponding schedule in the Notice which details the reporting requirements. Schedule 7 (Fuel combustion and flaring reporting requirements) of the Notice applies to all facilities involved in the activities listed below. For the 2018 calendar year, expanded data and prescribed methodological requirements only apply to facilities engaged in the activities and NAICS codes listed below:

Activities

  • mining
  • ethanol production
  • lime production
  • cement production
  • aluminium production
  • iron and steel production
  • electricity and heat generation
  • ammonia production
  • nitric acid production
  • hydrogen production
  • petroleum refineries
  • pulp and paper production
  • base metal production

NAICS codes

  • 212
  • 221112
  • 221119
  • 221330
  • 235120
  • 322
  • 324110
  • 325190
  • 325313
  • 327310
  • 327410
  • 331110
  • 331313
  • 331410
 

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64. Do I need to report electricity generation by each electricity generating unit?

Only facilities that are classified under NAICS 221112 are required to report electricity generation by each electricity generating unit. All other facilities subject to the expanded requirements are required to report electricity generation by facility. Refer to Schedule 7 in the 2019 Notice for greenhouse gas reporting for further details with regard to the expanded reporting requirements.

65. Why have the biomass emission factors been updated in Canada’s Greenhouse Gas Quantification Requirements (Tables 2-3 and 2-11 )?

The biomass emission factors originally published by ECCC required a correction to appropriately account for the moisture content of these fuels in 2018. The Department has further refined these factors in close consultation with the Forest Products Association of Canada (FPAC) and the National Council for Air and Stream Improvement (NCASI) in 2019.

66. Can I omit reporting the temperature and pressure conditions of gaseous fuel?

No, for gaseous fuel, you must indicate the temperature and pressure corresponding to the reported fuel quantity. Availability of this data improves the transparency of the reporting process, and helps ensure that standardization of fuel quantities is done consistently.

67. Cogeneration produces both electricity and steam simultaneously. How do I allocate the associated emissions into steam and electricity?

If you are unable to determine the actual quantity of fuel used for each purpose, you may allocate emissions according to the ratio of generated electricity (in megajoules) to generated heat (in megajoules).

68. My purchase records for natural gas often overlap between years in December and January. Can I assign fuel consumption to the bill or invoice date, rather than the actual consumption date?

You must assign fuel consumption to the actual consumption date, because the reporting requirement is for emissions that occurred in your facility during the calendar year. The data that you use to calculate emissions from your facility must reflect actual fuel consumed during that period.

69. My natural gas bill denominates it on an energy basis. How do I determine and report the quantity of natural gas?

The reporting system does allow you to input fuel quantities in energy units.  However, it is also possible and could be more useful in some cases to use the high heat value (energy conversion factor) that is available from your natural gas supplier to convert your natural gas consumption to volumetric units. If the information provided by the supplier is not in standard temperature and pressure for gaseous fuel, then you must convert the volumetric fuel quantity to standard conditions (cubic meters at 15°C and 101.325 kPa).

70. My facility is engaged in ammonia production. Is my facility subject to the requirements under the ammonia production Schedule 13 and hydrogen production Schedule 15 of the 2019 Notice for greenhouse gas reporting?

No. Emissions associated with hydrogen production are already accounted for in Schedule 13 under ammonia production reporting requirements.

71. I am a pulp and paper facility and I operate a lime kiln onsite. Am I subject to the lime production reporting requirements described in Schedule 8 of the 2019 Notice for greenhouse gas reporting?

For lime kilns at pulp and paper facilities, report using Schedule 17 of the 2019 Gazette Notice. Pulp and paper facilities are also subject to the requirements under Schedule 7 (Fuel combustion and flaring).

72. I am a petroleum refinery and I produce on-site hydrogen gas. Where do I find the requirements to report on my activities associated with hydrogen production?

For a petroleum refinery that is engaged in hydrogen production, you must report using Schedule 15, of the 2019 Notice for greenhouse gas reporting. Petroleum refineries are also subject to the requirements under Schedule 7 (Fuel Combustion and Flaring) and Schedule 16 (Petroleum Refineries).

Expanded quantification requirements

73. My facility is not within the sectors identified for the first and second phases of the federal Greenhouse Gas Reporting Program expansion. Can I use the quantification methods described in the quantification requirements?

Yes, you can use the methods in the quantification requirements document that are applicable to the emission sources of your facility’s operation. For example, you can use some of the methods described in the fuel combustion section (Chapter 2) if your facility burns fuel to generate energy or useful heat, or if you have on site transportation emissions to report.

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74. Do I have to report for all fuels that are combusted in my facility, no matter how insignificant their CO2 emissions are?

No. If the sum of CO2 emissions from the combustion of one or more fuels does not exceed 0.5% of your facility’s total CO2 emissions from fuel combustion, then you do not have to report these fuels or their emissions.

However, you must still report for all other fuels that are combusted in your facility.

75. Can I use a default value instead of a measured high heating value (HHV) to calculate emissions from fuel combustion?

No. None of the methods for fuel combustion described in the quantification requirements allow you to use a default higher heating value.

76. My facility integrates its coal mine to its power plant (a coal-to-mouth operation), so the concept of individual “fuel shipments” does not really apply to the coal that it consumes. Can I instead use continuous sampling for coal?

If coal is delivered continuously, you must sample as often as is necessary to capture the variation in carbon content and high heat value of the coal feed (not less than monthly), to ensure a representative annual composition of the coal consumed. You must document the approach used to determine this representative value.

77. If my facility uses a Continuous Emissions Monitoring System (CEMS) to obtain emissions information, are all of the non-emissions reporting requirements still required?

If a facility is subject to expanded reporting requirements, there are non-emissions reporting requirements even if using a CEMS. However, these mandatory reporting requirements, depending on the activities undertaken at the facility, are often different for facilities using CEMS. The majority of reporting schedules contained in the annual Notice include a paragraph which specifically outlines the mandatory reporting requirements for facilities using a CEMS.

Carbon capture, transport and storage

78. What is carbon capture, transport and storage (CCTS)?

A CO2 carbon capture, transport and storage facility (CCTS system) consists of some, or all, of the following components:

  • CO2 capture includes all infrastructures, equipment and process modifications designed to capture otherwise vented CO2 emissions
  • CO2 transport includes the transport of CO2 by pipeline, or other system, used to transport CO2, within Canada, from the capture facility to the injection facility
  • CO2 storage is a long-term geological storage facility. This includes sites injecting CO2 both directly into deep saline aquifers and into enhanced fossil fuel recovery operations, with the final goal of long-term storage
79. If my CCTS facility’s emissions were below the reporting threshold, do I still have to report for the facility?

Yes, you must report for your CCTS facility regardless of its total annual emissions. Required reporting for such a facility is listed under Schedule 6 of the annual Notice. If the facility’s total emissions are below the reporting threshold, then the facility is only subject to reporting under Schedule 6 and does not have to report the emissions data required under Schedule 5. In the reporting system, you can complete your reporting for this type of situation by selecting N/A throughout the sections that collect Schedule 5 data and providing a comment at the end of the report to notify the program.

80. I operate a CCTS facility. Do I report for previous years, in addition to reporting for 2018? Do I also report emissions from non CCTS activities that occurred in my facility during 2014 to 2017?

In 2017, you were required to report your facility’s annual greenhouse gas emissions and other information related to your CCTS activities for each of the 2014 to 2016 calendar years, in addition to the 2017 calendar year. For non CCTS activities that occurred in your facility during the 2014 to 2016 calendar years, you are required to follow the reporting requirements published for those years.

Since 2018, there are no retroactive reporting requirements published for CCTS activities. You must simply follow the requirements published in the notice applicable to the year for which you are reporting.

81. My facility injects CO2 into enhanced fossil fuel recovery operations. Do I have to report my facility?

You must report for the quantities of injected CO2 along with fugitive emissions from associated injection equipment, CO2 transport network,and CO2 losses from the injection site.

Fuel combustion

82. My facility generates electricity in multiple units, but it is not an electric utility (NAICS 221112). Do I have to report electricity generation for each unit separately?

No. This is a requirement only for facilities that report under NAICS 221112. The reporting system, however, is set up to accept reporting for each unit. In this situation, you may simply report all electricity generation and associated emissions under a single unit, whether there are multiple units or not.

83. My facility generates electricity in multiple units, some of which do not produce greenhouse gas emissions (e.g., steam turbines powered via recovered heat/steam, wind turbines). How do I report the electricity generated by these units without reporting emissions?

There is now an additional field added to the reporting system for these situations. For these particular units/turbines, if they in fact do not generate greenhouse gas emissions, do not enter their information where you would enter the information for the other units/turbines as that electricity generation section requires input of fuel and emissions data. Instead, near the bottom of the fuel combustion reporting screen, there is a section for ‘Electricity Information’, which includes a field for ‘Additional electricity generated on-site’. This is where you may enter the electricity generated for these units/turbines. It is also encouraged to include a comment in your report to inform the program of the set up at the facility.

84. My facility purchases and uses gasoline and diesel fuel. These fuels are blended with ethanol and biodiesel respectively. Is this blend accounted for in the emission factors provided for reporting purposes?

No. In the case of blended fuels, it is the responsibility of the facility to report each fuel type separately. When purchasing fuels, ensure that you obtain the fuel blend from the supplier so that you may accurately separate and calculate emissions by fuel type for reporting purposes. This will then ensure that you not only report volumes and emissions accurately by fuel type, but also by biomass or non-biomass CO2. Note that biomass CO2 emissions, while required to be reported, are not added to the facility total emissions.

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Contact us

Federal Greenhouse Gas Reporting Program

Environment and Climate Change Canada
Pollutant Inventories and Reporting Division
Place Vincent Massey, 7th Floor
351 St. Joseph Boul
Gatineau QC  K1A 0H3

Telephone: 819-938-3258
Toll-free: 1-877-877-8375
Email: ec.ges-ghg.ec@canada.ca

Alberta Environment and Parks

Telephone: 780-427-5200
Email: AEP.GHG@gov.ab.ca

British Columbia Ministry of Environment

Email: GHGRegulator@gov.bc.ca

Newfoundland and Labrador Office of Climate Change

Telephone: 709-729-1210
Email: statenv@gov.nl.ca

Nova Scotia Climate Change

Email: GHGreporting@novascotia.ca

Ontario Ministry of the Environment and Climate Change

Telephone: 416-649-4480
Toll-free: 1-855-815-6400
Email: GHGReporting@ontario.ca

Quebec Ministry of Sustainable Development, Environment, and Action against Climate Change

Telephone: 418-521-3833
Email: declaration.atmosphere@mddelcc.gouv.qc.ca

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