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Changes are coming to Oregon’s greenhouse gas reporting program—are you ready?

July 21, 2020

By Yasmeen Sultana

If you’re reporting 25,000 MT CO2e GHG emissions or more, the time to get ready for Oregon’s newly revised regulations is now

Changes are coming to the State of Oregon’s reporting program for greenhouse gas (GHG) emissions. How can you get ahead of the new requirements?

If you’re required to report GHG emissions, and if you expect your 2021 annual emissions to be equal or greater than 25,000 MT CO2e, the time to get ready for Oregon’s newly revised regulations is now.

So, what are the new requirements? According to the Oregon Department of Environmental Quality (DEQ), Oregon’s Environmental Quality Commission (EQC) is requiring certain regulated entities to have their GHG emission data third-party verified annually. That verification will improve data reliability. It will also ensure that large GHG emitters are accurately calculating emissions and correctly meeting DEQ’s reporting requirements.

Changes are coming to the State of Oregon’s reporting program for greenhouse gas (GHG) emissions.

What’s the current landscape in Oregon?

Let’s begin with some background. In 2008, the EQC adopted the initial greenhouse gas reporting rules to collect comprehensive data about Oregon’s overall GHG emissions. The rules govern the collection of annual reports of emissions and related information from certain entities, including large commercial, institutional and industrial emitters, fuel suppliers, and electric utilities. Oregon’s reporting program helps provide a better understanding of emissions and improves the ability to track progress toward meeting emission-reduction goals established by the state. The EQC adopted rules in 2010 and 2015 to expand the number and types of facilities and operations required to report and to align reporting requirements with the U.S. Environmental Protection Agency.

What’s changing? Reported GHG emissions for larger sources will now have to be verified annually by a third party. The new/revised rules will do the following:

  • Modify greenhouse gas reporting to improve specificity and require the reporting of data essential to informing Oregon climate policy
  • Streamline language allowing fuel suppliers subject to both the Clean Fuels Program (CFP) and GHG to report into a single system
  • Update enforcement provisions to allow for proper regulation of requirements
  • Require third-party verification, starting with the verification of 2021 emissions in 2022. This applies to GHG reporting program entities that report annual anthropogenic emissions equal to or greater to 25,000 MTCO2e

These changes and improvements will allow the program to better support and keep pace with the evolving climate policy discussions in Oregon.

Because the third-party verification process will begin in 2022, with an analysis of GHG emissions data from 2021, it’s important to prepare now.

I’ve spent the last 10 years helping the industry in California get ready for similar third-party GHG verifications. Here’s what I’ve learned about how to navigate the verification process and what Oregon businesses need to know.

Not all gaps are equal. It’s a good idea to prioritize your gap-closure process based on the risks presented by each gap.

Gap assessment

When I’ve helped clients in California prepare for a third-party assessment, I begin with a gap assessment.

We start with looking at the GHG emission requirements for your facility. How does the facility meet the requirements? Next, we determine if gaps exist that will prevent you from meeting the requirements.

What type of gaps should you be looking for? The initial but critical gaps can include:

  • Incomplete understanding of applicability
  • Missing GHG equipment or processes from the report
  • Measurement inaccuracy (for example missing or uncalibrated meters)
  • Missing fuel sampling frequencies, processes, and data
  • Inaccurate calculation methods
  • Incomplete records that may be needed for successful verification

Let’s say your data is based on quarterly sampling, but you’re only sampling twice per year. There’s a gap that is going to impact your results.

Or let’s say your emissions must come from a calibrated meter (demonstrating 95% accuracy) but your meters were never calibrated to that standard. Another gap.

Or maybe your meters aren’t even located in the right places to collect the right data necessary for emissions calculations. We help figure out a metering strategy that satisfies the regulatory requirements with the least impact to operating costs.

How will you successfully navigate Oregon’s new GHG emissions verification process?

Gap closure

After the gap assessment is complete, we move onto gap closure. How do we address the gaps that will impact your verification, and where do we begin?

Not all gaps are equal. It’s a good idea to prioritize your gap-closure process based on the risks presented by each gap. For example, a gap that has the potential to impact your emissions by more than 5% might be prioritized ahead of other gaps that might be more administrative, such as record keeping.

In another example, preparing a monitoring plan that meets the regulatory requirements might be prioritized over other optional documentation.

Verification process review

Finally, we review the verification process. If there isn’t already a verification process in place, we recommend you establish one. This may include:

  • Developing protocols for communication and verification process management
  • Identifying roles and responsibilities
  • Identifying key individuals who may be interviewed
  • Pre-verification training, including conducting mock verifications with your team


By preparing now for Oregon’s coming Third Party Verification of GHG emissions in 2022,  you’ll ensure that you meet the new GHG requirements, that you understand and proactively address any potential areas of concern, and that you have a plan to obtain a positive verification outcome.

  • Yasmeen Sultana

    Yasmeen is an air quality expert providing technical support related to emerging air, greenhouse gas, and methane regulations. She helps upstream and midstream oil and gas, power, utility, and manufacturing clients comply with mandatory reporting.

    Contact Yasmeen
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