Spotlight on Greenhouse Gas Emissions Inventory Services
Greenhouse Gas Emissions Inventory Services
Liberty Environmental has been helping our clients track their greenhouse gas (GHG) emissions (“carbon footprint”) for over 15 years with both voluntary reporting programs like the Carbon Disclosure Project and also with mandatory reporting programs like the U.S. EPA “Part 98 Greenhouse Gas Reporting Rule”. Our Air Quality practice team has extensive experience estimating GHG emissions for manufacturing operations, buildings/warehouses, and for transportation/distribution operations.
Liberty’s GHG inventory services date back to 2005 when we started assisting an international consumer products company with voluntary GHG reporting and sustainability planning services. Our client reports GHG emissions through the international Carbon Disclosure Project (CDP) that requires annual inventories of Scope 1, Scope 2, and Scope 3 emissions. Liberty calculates GHG emissions for manufacturing plants, offices, distribution operations, and employee travel for locations in 16 different countries and 30 U.S. states. Scope 1 emissions are calculated for fuel usage at each of the locations including natural gas, fuel oil, and biomass. Biomass-related CO2 emissions are reported separately as “biogenic” emissions because biomass is renewable. Scope 2 emissions are calculated based on electricity usage at each location and local energy grid GHG factors. Scope 3 GHG emissions are optional and our client has chosen to report those emissions associated with product distribution and has demonstrated reductions in these emissions through improved transportation logistics and the introduction of concentrated products with less packaging.
Mandatory reporting of GHG emissions from large sources in the U.S. began in 2010 when the federal Part 98 GHG reporting rule came into effect. Facilities that emit more than 25,000 metric tons per year of GHG emissions are subject to Part 98 reporting and must report electronically using EPA’s electronic GHG reporting tool, e-GGRT. Liberty also supports manufacturing clients and electric/steam combined heat & power (CHP) facilities in reporting their GHG emissions annually though the e-GGRT system.
In addition, our team has provided the oil/gas industry with air permitting services that include estimation of methane emissions and GHG inventories for gas compressor station operations. Methane is a potent GHG gas and methane emissions reporting is required in Pennsylvania.
New York City Local Law 97
Our licensed Professional Engineers assist building owners in New York City with the new Local Law 97 compliance, which requires annual GHG reporting and imposes phased-in GHG emission limits with substantial monetary penalties for buildings that exceed the limits.
New York City enacted Local Law 97 in 2019 as part of the Climate Mobilization Act in an effort to reduce GHG emissions from large buildings 40% by 2030, and 80% by 2050. The Law regulates GHG emissions from buildings with more than 25,000 gross square feet. Reporting is required annually beginning May 1, 2025 for calendar year 2024 emissions, and penalties will be assessed at a rate of $268/ton based on any GHG emissions in excess of the allowable limits. Because GHG emissions from a building 100,000 sq ft in size can be about 1,000 tons/year of GHG emissions, the penalties for excess emissions from an older building that is not retrofitted with energy efficient technologies could easily be in the range of $50,000 to $100,000 per year. If GHG emissions cannot be achieved through energy efficiency measures, the law allows the purchase of renewable energy credits or carbon offsets. Because of the future cost implications of this law, building owners and prospective buyers are encouraged to evaluate the impacts of Local Law 97 on building operating costs well in advance of the 2024 reporting year.