Dec

9

Harmonization of WCI Reporting Program with EPA Mandatory Reporting Rule

Filed Under Western Climate Initiative 

WCI Partner jurisdictions are currently in the process of adopting rules to implement the WCI’s final Essential Requirements for Mandatory Reporting (ERs), which were issued on July 16, 2009. On September 22, 2009, U.S. EPA adopted its final Mandatory Reporting Rule (MRR) for greenhouse gas (GHG) emissions. Both programs require the filing of initial reports in 2011 for the 2010 reporting year. Many U.S. facilities in the WCI region will be subject to both reporting programs.

In order to avoid the imposition of duplicative or conflicting reporting obligations on facilities subject to both programs, the WCI Partners have directed the Reporting Committee to amend WCI’s ERs to achieve harmonization with the EPA MRR. The harmonization effort will be guided by the following principles:

  • A U.S. facility should be able to comply with both the MRR and a WCI jurisdiction’s reporting requirements by following a single set of monitoring, recordkeeping and reporting requirements.
  • The quantification methods included in the amended ERs must be sufficiently reliable and accurate to be employed in a (GHG) cap-and-trade program. Because EPA has acknowledged that it did not develop the MRR with this goal in mind, the Reporting Committee must review each method included in the MRR to assure it meets this criterion.
  • The amended ERs must remain suitable for use in Canadian WCI jurisdictions. For example, they must allow reporting in metric as well as English units and must where necessary include Canada-specific emission factors.

The WCI Partners recognize that the detailed analysis, redrafting and stakeholder review required to harmonize the existing WCI ERs with EPA’s MRR cannot be accomplished in time for the 2010 reporting year. As an interim measure, the U.S. WCI Partner jurisdictions intend to include in their rules a provision that will allow facilities to comply with the jurisdiction’s reporting rules for the 2010 reporting year by submitting a copy of the reports they file with EPA under the MRR. Although this approach may result in some inconsistencies in the data submitted for 2010, the Partners believe that is preferable to the potential imposition of duplicative or conflicting reporting obligations.

The WCI is also engaging with Environment Canada to harmonize reporting requirements.

The WCI’s goal is to adopt ER amendments that achieve consistency across the region and with the MRR in time for the 2011 reporting year.  Further details on the Reporting Committee’s workplan to harmonize reporting requirements is available here.