Beveridge & Diamond
Related Practices
Related Practices

Mandatory Carbon Reporting Approaches As The Climate Registry Releases Reporting Protocol For GHG Emissions Tracking

Beveridge & Diamond, P.C., April 3, 2008

The Climate Registry (“TCR”), a prototype national carbon registry with 39 U.S. member states, released the final version of its General Reporting Protocol (“Protocol”) on March 31.  The Protocol provides guidance to reporting entities on how to calculate and report greenhouse gas emissions, and is being developed in advance of mandatory greenhouse gas reporting rules currently under development by the U.S. Environmental Protection Agency (see B&D Alert, dated 2/21/08).

The TCR and EPA reporting databases will be linked through a data-sharing agreement.  The Protocol includes policy and technical guidelines and methodologies for quantifying and reporting emissions of six principal greenhouse gases:

  • carbon dioxide
  • methane
  • nitrous oxide
  • perfluorocarbons
  • hydrofluorocarbons
  • sulfur hexafluoride

Reporting will be by gas and source, reported separately for each facility.  Reporters also have the option of including worldwide emissions or emissions related to employee travel, and/or additional greenhouse gasses.  Both direct emissions, such as those created through burning of fossil fuels, and indirect emissions, such as those created by purchased electricity, are reported but are tracked separately. 

To ensure the accuracy and credibility of the reported emissions data, the Protocol requires reporting entities to use a third-party verifier to assess their emission reports annually.  TCR recently issued its General Verification Protocol, which provides guidance on how to verify reported emissions.  In the future TCR plans to develop sector-specific protocols to provide guidance to individual industry sectors.

The TRC was established in 2007 as a non-profit organization to serve as a common voluntary reporting registry by participating states, tribes, and Canadian provinces.  TCR’s membership currently covers 80 percent of U.S. and Canadian populations, and includes thirty-nine U.S. states and the District of Columbia, eight Canadian provinces and territories, six Mexican states, and three Tribal Nations.  Seventy-five companies and other entities, such as local governments, have signed on as “founding reporters” of TCR.  Companies have until May 1, 2008 to sign on as a founding member.

Companies are encouraged to consider joining The Climate Registry for a number of reasons including: (1) preparing for EPA’s mandatory reporting, which is expected within the next year; (2) managing risks of anticipated carbon regulation, such as cap-and-trade laws in California, the Western Climate Initiative, the Midwestern Greenhouse Gas Reduction Accord, New England’s Regional Greenhouse Gas Initiative, and likely federal legislation such as the Warner-Lieberman bill; (3) recognition for environmental leadership; (4) possible crediting of early actions to report and reduce GHG emissions; (5) participation in key policy decisions; and (6) access to technological resources.

To access the GRP, click here.

For more information contact Max Williamson at (202) 789-6084 or, Nicholas W. van Aelstyn at or (415) 262-4008, or Suzanne Piluso at or (415) 262-4013.