Preparing for Climate Change and Greenhouse Gas Regulations

By Brandon Bass, PE, MBA

It’s no secret that the Biden administration is set on addressing climate change and greenhouse gas (GHG) emissions. Here are some recent headlines that highlight what we’ve seen:

•  Fight escalates over FERC gas, climate reviews (Energy Wire, 11/22/21),
• Schumer: Emissions reductions ‘not sufficient’ without meeting White House environmental justice standard (The Hill, 11/17/21),
• Biden Administration Moves to Limit Methane, a Potent Greenhouse Gas (New York Times, 11/2/21) and,
• The fight against climate change requires action not just words (The Economist, 11/8/21).

Whether you agree or disagree on the impact of climate change, the industry is facing increased legislation and regulation on greenhouse gases. With that in mind, we want to give you a few ideas and thoughts around how you and your company can prepare.

Benchmarking

According to the American Society for Quality, Benchmarking is the process of measuring products, services, and processes against those of organizations known to be leaders in one or more aspects of their operations. For our purposes, we want to look at and compare GHG emission data.

The US has been collecting GHG emissions data for large facilities for almost 10 years, and it is all publically available in the Environmental Protection Agency’s (EPA) Facility Level Information on GreenHouse gases Tool (FLIGHT). The FLIGHT database summarizes GHG emissions by industry sector, by state, by facility, by year, etc. The data can be displayed in tables, charts, and trend lines.  You can even show facilities on a map and zoom into your facility or see the surrounding facilities.

The Bottom Line: there’s A LOT of data, it’s all public, and it’s  very easy to compare.

The question is: how does your facility’s benchmark compare?

Here are some things to consider as you benchmark your facility:

•  Are you subject to the GHG Reporting Program (40 CFR Part 98) and have you been reporting?
• Are you a top emitter in your category?
•  Are you a top emitter in your state or county/parish?
• Are you a top emitter on a production basis (emissions/production level or throughput basis)?

If your facility falls short during your benchmarking comparison, now is the time to start planning on how to address your GHG emissions. 

Source Analysis

The next step would be to complete a source analysis to determine which sources are contributing the largest to GHG emissions from the overall facility.

If you are submitting GHG emissions under the GHG Reporting Program then you may already know this information. Nevertheless, it would be a good exercise to go through to understand where GHG emissions reductions would be best served.

If you are submitting GHG emissions data under the GHG Reporting Program, have you benchmarked your sources against other facilities in your industry? For example, you can drill down on a refinery’s emissions by source. You can then compare if your cracking unit is in line with other refineries or if it is much higher.

Identifying source trends in your industry can help prepare you for future scrutiny or regulatory pressure. Furthermore, if you have obvious outliers in your emission sources, then chances are good that this would be the first place regulators would address and a good place to focus your reduction efforts!

Reduction Plans/Goals

Does your company have an emissions reduction plan or goal?

It’s becoming more commonplace for companies, especially large publicly traded companies, to implement emissions reduction plans or goals. Companies are starting to implement carbon reduction or carbon-neutral goals as more and more shareholders are factoring in environmental social governance into their investing decisions. 

If your company has a plan/goal in place, here are a few thoughts to consider:

• Do you agree with this goal? Do you think this is achievable?
•  How can you as an operations or environmental employee support these goals?
•  Would you recommend any tracking or emissions reduction projects?
•  Does the company plans/goals align with your benchmarking and source analysis?
• Is there anything that is missing?

Alternatively, if you don’t currently have any emissions reduction plans/goals, here are some thoughts to consider:

• Many times, emissions reduction projects go hand-in-hand with some type of efficiency improvement project.Have you performed a cost-benefit analysis to factor in any potential financial benefits?
•  What obstacles are preventing you or your company from implementing these goals?
• Based on your benchmarking and source analysis, what areas do you need to focus on?
• How can you as an environmental employee support driving the creation of emission reduction goals or plans?
•  Would you recommend any tracking or emissions reduction projects?

Anticipate & Plan Ahead

It’s good to start thinking and planning now for the current administration’s stance on climate change and their goals of reducing GHG emissions. Benchmarking helps identify if your facility or single process is an outlier for emissions. Completing a source analysis can help determine which process/sources need to be prioritized. Using the results from benchmarking and your source analysis can help drive GHG reduction plans and goals.

PPM Consultants has several technical experts on staff who are familiar with the GHG Reporting Rule and help facilities think through and implement compliance and reduction goals. If you have any questions or would like to discuss your facility’s greenhouse gas emissions please feel free to reach out to me directly via email at brandon.bass@ppmco.com. And, if you’re interested in this, check out PPM’s podcast episode on GHG Emissions where we discussed this topic in more detail. 

Contact us now to get in front of the regulatory wave that is beginning to form!

Let us help you plan for upcoming GHG regulation!

As has always been the case, the future is difficult to predict. But by planning now for future regulations, you ensure a smooth transition with even smoother operation tomorrow. Don’t wait for regulations, anticipate and plan ahead for them with PPM Consultants. To learn more, call 1-800-945-4834 or contact us here.