U.S. Federal Mandatory Greenhouse Gas Emissions Reporting Audit Protocol
Author: Jon F. Elliott Esq., MPP (founder and President of Touchstone Environmental Inc.)

U.S. Federal Mandatory Greenhouse Gas Emissions Reporting Audit Protocol is a tool to be used to assess whether entities—owners and operators of facilities in sectors that burn substantial fuels or use greenhouse gases (GHGs) and selected suppliers of fuels and GHGs—are sufficiently prepared to submit annual GHG emission reports. Emissions are monitored and calculated each year and reported by March 31 of the following year, as mandated by the Environmental Protection Agency (EPA) beginning in 2010.

This publication provides a procedural audit protocol to help owners or operators of facilities that are preparing for an audit, and to help new or experienced auditors thoroughly identify the GHG reporting challenges facing the entity, and to determine if the entity is in compliance with the existing regulations. 

U.S. Federal Mandatory Greenhouse Gas Emissions Reporting Audit Protocol covers rules the EPA has codified in 40 CFR 98. These include general rules from subpart A of 40 CFR 98 that are applicable to all sectors. They also include sector-specific rules for 30 different sectors, which appear in subparts C through PP of 40 CFR 98 (EPA has reserved subparts B, I, J, L, M, T, W, DD, GG, II, and KK for future additions). This publication covers these rules under the following rulebook parts:

• Entities Subject to Mandatory Greenhouse Gas Reporting (Rulebook Part 3A) – EPA specifies entities that must comply with GHG reporting requirements in 40 CFR 98. This part covers qualifying thresholds under which a designated entity (facility or supplier of specified fossil fuels or GHGs) in each sector is required to prepare and submit GHG emission reports.
• Requirements Applicable to All Reporting Sectors (Rulebook Part 3B) – If an entity is a facility with one or more sources subject to 40 CFR 98, or is a supplier subject to 40 CFR 98, then it must prepare and submit an annual GHG emission report to EPA. This part describes general reporting requirements applicable to all reporting entities.
• Additional Requirements Applicable to Facilities in Specific Sectors (Rulebook Part 3C) – EPA applies 40 CFR 98 GHG emission reporting requirements to facilities that contain “downstream” end uses of fuels and other GHGs that produce emissions. This part is divided into 25 sections that cover sector-specific regulations found in subpart C through subpart JJ of 40 CFR 98. 
• Additional Requirements Applicable to Specific Sectors of Materials Suppliers (Rulebook Part 3D) – EPA also applies 40 CFR 98 GHG emission reporting requirements to specified “upstream” suppliers of fuels and gases that produce emissions when combusted or consumed. This part is divided into 5 sections that cover sector-specific regulations found in subpart LL through subpart PP of 40 CFR 98.

This GHG Emissions Reporting Audit Protocol  is one of a series of audit protocol modules developed as part of a new two-volume publication entitled Managing Climate Change: A Practical Guide to Voluntary and Required Actions.  This publication will be available later in 2010.

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