Trinity has extended its third-party verification services to The Evergreen State. Trinity is already a verification body
accredited by California,
certified by Oregon, and has recently obtained certification from the Washington Department of Ecology (Ecology).
Who Gets Verified?
Both Washington Administrative Code (WAC) 173-441 GHG Reporting and Verification and WAC 173-446 the Cap-and-Invest program under Climate Commitment Act include verification requirements. According to WAC 173-441-085, mandatory verification is required for any year emissions (including biogenic) exceed 25,000 metric tons of CO2e beginning with the 2023 emission year. This requirement also applies to cap-and-invest participants with a mandatory or voluntary compliance obligation. Emission reductions through the offset projects will need to be verified if used for compliance demonstration under the Cap-and-Invest program.
What to Expect for the Verification Process
Before verification can begin, facilities must send a notice of verification service and supporting information to Ecology that shows their contract with a third-party verifier and Ecology will confirm no high conflicts of interest. Ecology must approve the verification relationship before the process can proceed.
A verification team includes a lead verifier, supporting verifiers, and possibly a sector specialist. A site visit and interviews with key staff are required for a full verification, which will be required in 2024. Facilities should coordinate with their verifiers to ensure compliance with the verification requirements.
Verifiers will assess material misstatement and may identify correctable errors after examining emissions reports. These errors must be fixed, and a revised GHG report must be submitted by the deadline of August 10, 2024 to receive a positive verification statement.
Best Practices for A Smooth Verification Process
Start Early
The verification report for the 2023 emission year must be submitted by August 10, 2024, as stated in WAC 173-441-085(6)(a). The verification process usually takes three to four months from the date Ecology approves the verification relationship until the date the verification statement is submitted. A couple of things to consider:
- Fixing correctable errors takes time. The verification team may find errors during data checks, and the errors may be complex and take several weeks to fix and resubmit. Ecology will take two to three days to process your corrected report and the verification body may take one to two weeks to do the final checks. However, you still must meet the deadline of August 10, 2024, even if you have errors to correct. We strongly advise you to start the verification as early as possible to allow enough time for revisions.
- Engage a verification body soon. A full verification is required in 2024, which includes a site visit. Assuming you submit your 2023 GHG emissions inventory by March 31, 2024, which is the regulatory deadline, and the verification process takes four months, you will only have ten days left to correct any errors, send updates to Ecology, and receive the verification statement by the verification body. Therefore, we recommend submitting your 2023 GHG emissions inventory as soon as you can, engage a verification body, and arrange the site visit soon.
Documentation
A full verification involves a site visit, but most of the verifier’s work consists of reviewing documents, such as the GHG inventory report and the GHG Monitoring Plan. Other relevant documents include:
- Billing invoices to confirm fuel usage;
- Maintenance records to confirm instrument calibration checks;
- Annual product data for emissions intensive trade exposed (EITE) facilities in the Cap-and-Invest program to calculate carbon intensity in the compliance year.
The GHG Monitoring Plan is a key document that guides the GHG emissions reporting process. It should comply with WAC 173-441-050(6)(e), which differs from the federal mandatory reporting rule under 40 CFR Part 98. As a best practice, Trinity recommends documenting the basis for exempt emission units and fuel use. If there are changes to the calculation methodology, the GHG Monitoring Plan should be updated accordingly to match the reported data. Further, how product data is determined, and the accuracy of the data should also be discussed in the GHG Monitoring Plan.
Companies may have their own record retention policy but be aware that all documents related to GHG emission reports must be kept for 10 years, including calibration and maintenance records.
Consider Completing a Mock Verification
A mock verification service from Trinity can help facilities assess their readiness for the third-party verification of GHG reports. Trinity will evaluate the GHG Monitoring Plan of the facility and confirm if it complies with the regulatory requirements. During the actual third-party verification, verifiers are not allowed to give guidance on how to fix errors. The mock verification aims to help you correct any errors to improve your GHG reporting and management practices. Drawing on our extensive experience in verification support in California and Oregon, Trinity will offer best practices that suit your operational needs.
Next Steps
Trinity is a trusted verification partner for clients in California and Oregon. We can help you get ready for the upcoming verification in Washington. Whether you need a mock third-party verification or a full verification service, Trinity is here for you. If interested, please contact
Hui Cheng or call
253.262.5888.
