What businesses need to know about Washington State's greenhouse gas reporting program

Authors: Stepheney Davey, Yashashwini (Ruchi) Hamal and Peter Tkalec
Industrial smoke from chimney

Starting early next year, businesses that report over 25,000 of CO2 per year will require third-party verification of their greenhouse gas emissions reports as part of Washington’s Climate Commitment Act. We support clients with independent, impartial greenhouse gas verification and validation services to meet the new requirements.


Washington’s Climate Commitment Act and greenhouse gas verification program

In response to Washington State’s Climate Commitment Act (CCA), the Department of Ecology implemented an economy-wide Cap-and-Invest Program to address climate change and progress its overall commitment of reducing greenhouse gas (GHG) emissions by 95% by 2050. 

As part of the Program, starting in January 2024, entities are required to report their annual emissions under the State GHG Reporting System and those emissions must be verified for accuracy by an independent third party in a goal to better understand the amount and sources of carbon pollution in the state. 

The verification requirements will apply to all 2023 emissions data reports, for which the verification deadline will be August 10, 2024, and requirements will continue for future annual GHG emissions reports. The verification process involves an independent third-party performing a complete review of the reported emissions, emission sources, and product data from each site of a regulated entity. The verification body must meet the regulatory qualifications prescribed by the Washington State Department of Ecology.

In response to Washington State’s Climate Commitment Act (CCA), the Department of Ecology implemented an economy-wide Cap-and-Invest Program to address climate change and progress its overall commitment of reducing greenhouse gas (GHG) emissions by 95% by 2050.

How this affects Washington businesses

A business may be required to retain a third-party verifier to have its emissions data report verified if it is expected to meet the following thresholds:

  • A reporter who emits, produces, imports, or delivers emissions equal to or greater than 25,000 metric tons of CO2e, including biogenic CO2 emissions in 2023 must participate in the CCA cap-and-invest program as a mandatory requirement.
  • An opt-in CCA cap-and-invest participant with a voluntary compliance obligation. 

There are additional requirements and exemptions from the program, for further information please feel free to reach out to us.

How to get started to comply with the new requirements

Businesses that are required or who will voluntarily opt in to the CCA program should contact a qualified third-party greenhouse gas verification and validation specialist. Acting early will help you identify best practices for reporting and ways that could help manage your greenhouse gas emission reporting.

We have been actively involved in providing verification services since the inception of regulatory and voluntary greenhouse gas reporting programs and have assisted our clients with quantifying their GHG emissions for over 20 years. With our extensive experience, our verification teams help navigate through the verification process with confidence.

The validation and verification process

Using a risk-based approach, we determine the scope of the verification that is unique to each site. The key risks involved with the GHG emissions data are assessed and mitigated through the verification process to achieve a reasonable level of assurance for every client.

Third-party verifications are done in compliance with Washington’s Greenhouse Gas Reporting and Verification: Third-Party Verification Guidelines. The process includes setting a verification plan, reviewing the reporter’s operations and data, creating sampling plans, conducting site visits, completing data checks, correcting any report errors, summarizing the findings, completing a review of any missing data or misstatements and writing a detailed verification report.

Following the verification services, a statement, form, and report are submitted to the Department of Ecology for final approval.

Our validation and verification services follow the standards of service set forth by the International Organization for Standardization (ISO) and we are accredited for all sectors under this ISO 14065 standard. Our verifiers are currently in the process of becoming Washington-certified under the Washington Greenhouse Gas Third-Party Individual Verifier Certification and Specialist Trainings and we anticipate obtaining certification well in advance of the 2024 reporting deadlines.

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Part of a growing greenhouse gas verification movement

Greenhouse gas verification programs have been growing in popularity over the past several years. We have experience preforming verifications across North America including the following:

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