The Canadian Greenhouse Gas Reporting Program (GHGRP) operates on a two-tier system, meaning Canadian businesses must file a federal GHG emissions report and a provincial one. In many provinces, the relevant air regulations can differ substantially between the federal and provincial levels, making it difficult for many businesses to keep up.
Below is a brief summary of the key reporting requirements for greenhouse gas emissions for most of the bigger provinces in Canada, so that you may get an idea of the differences between the federal regulations and the provincial GHG rules that apply to your facility.
But given that there are too many GHG reporting requirements to list in a single article, be sure to check in with your province's Ministry of Environment when reporting season comes around. Remember, there are many good reasons, beyond legal obligation, to report your GHG emissions properly.
Alberta: Specified Gas Reporting Standard
Alberta’s GHGRP, known as the Specified Gas Reporting Standard, is nearly identical to the federal program. The threshold for greenhouse gas reporting is set at 10,000 tons of CO2e emissions released in a calendar year, there are 24 GHGs with the same Global Warming Potential (GWP) values, and the deadline to submit (through the federal SWIM system) is June 1st.
The province used to require facilities to include carbon dioxide emissions from the combustion of biomass materials in their threshold calculations, but this is no longer the case as of 2018, when biomass emissions were removed from direct emissions. However, biomass CO2 emissions are still a reported emissions category, as is the case at the federal level.
The sole element of provincial specificity for specified gas emitters seems to be the need to indicate Alberta-specific Greenhouse Gas Quantification Methodologies (AQM) where applicable. These take priority over Canada-wide quantification requirements and the UNFCCC's "Preparation of National Greenhouse Gas Emission Inventories" guidelines, and if none of them are met, the facility must submit a record of deviation with the report.
Since the Specified Gas reporting standard PDF is only 18 pages long, we thoroughly recommend reading it before preparing your annual submission.
British Columbia: Greenhouse Gas Industrial Reporting and Control Act
British Columbia's Greenhouse Gas Industrial Reporting and Control Act (GGIRCA) is, in many ways, one of the most stringent GHG reporting regulations in Canada.
All facilities registered as Reporting Operations are required to report, regardless of their overall GHG emissions. These facilities are those that met or exceeded the 10,000-ton threshold once in any of the three previous years; in other words, to be be declassified as a Reporting Operation, a facility must cease reportable manufacturing activities and emits less than 10,000 tons of carbon dioxide equivalent (CO2e) for three consecutive years.
There are a total of 32 activities that may lead Reporting Operations to have an obligation to report, each with its own emissions quantification methodologies.
Any Reporting Operation that emits 25,000 tons of Co2e or more during the current reporting cycle, or any of the previous three reporting cycles, must also get their emission reports verified by an accredited third party verification body. This rule also applies to all regulated liquefied natural gas (LNG) operations.
Industrial operations that emit less than 10,000 tons may voluntarily apply to be listed as a Reporting Operation, unless they produce regulated products and are approved to opt into the BC Output-Based Pricing System, in which case they are already considered to be Reporting Operations.
Lastly, as of April 2024, the report must include both emissions that are attributable for reporting purposes and those that are attributable for compliance purposes.
The official annual deadline to register for GHG reporting, submit emissions reports, and submit verification statements (all done through SWIM) is May 31st. Visit their guidance webpage for more information.
Manitoba: Climate and Green Plan Implementation Act
From our research, Manitoba's Industrial GHG Emissions Control and Reporting Act (itself part of the Climate and Green Plan Implementation Act) appears to be unique in that only industrial operations that emit 50,000 tons or more are obligated to report. Those with emissions between 10,000 and 50,000 tons (or who own/operate new or expanded facilities expected to fall within these boundaries) may opt in for designation as a reporting industrial operation.
This elevated threshold would mean that only Large Final Emitters, of which there were only 8 in the province back in 2018, fall under the scope of the act (opt-ins excluded).
One unique feature of Manitoba's GHG reporting guidelines concerns the compensation of excess emissions. Facilities that exceed their industrial GHG emissions limit must either remit them using offset credits (earned in compliance periods during which the facility stayed below the limit, provided they were not transferred to other facilities) at a rate of one credit per ton, pay a levy to the Crown at a rate of $25 per ton, or use a combination of both offset credits and levy payments.
Our team could not find a definite reporting deadline in the body of the act, but given that annual progress reports from the Minister are due on March 31st, it is likely facilities are required to report before that date.
New Brunswick: Reporting and Reduction of GHG Emissions Standard
The province of New Brunswick boasts a very detailed, 58-page regulation titled The Reporting and Reduction of GHG Emissions Standard. As stated explicitly in the document, the standard is "consistent in scope and methodology" with the federal one, in that the 10,000-ton/year threshold for greenhouse gas reporting applies, the report consists of the usual types of emissions (electricity generation, direct emissions, etc.) for a good number of the usual regulated sources of emissions (CO2, methane, sulphur hexafluoride... see Table 1 of the linked document), and the deadline to submit it (via SWIM) is June 1st.
Where New Brunswick's GHG reporting standard seems to differ from the federal GHGRP is in the establishment of a Baseline Emissions Intensity for each product at the facility.
The emissions baseline is obtained by dividing the average annual emissions of three consecutive calendar years by the average annual production level, and it is used, alongside information on the facility's reduction period, its Biomass Adjustment Factor, and its Risk Adjustment Factor, to determine the facility's emissions limit and performance standard—the amount of regulated emissions a facility is permitted to emit producing a unit of product in the given reduction period without incurring a compliance obligation. Baseline Emissions Intensity submissions are due September 30th of the first compliance period.
Both the GHG reports and the Baseline Emissions Intensity submissions must be verified prior to submission by an accredited verification team in accordance with the ISO 14064-3 standard.
Moreover, facilities that have compliance obligations must follow up on their annual submission with a Compliance Report demonstrating how they have met these obligations by purchasing fund credits, obtaining performance credits awarded by the Minister, or obtaining offset credits granted or recognized by the Minister. These reports are due on December 15th.
Nova Scotia: Greenhouse Gas Emissions Regulations
Nova Scotia is a rather unusual case, as far as their Greenhouse Gas Emissions Regulations go.
While individual facilities are subject to the standard threshold of 10,000 tons of CO2e emissions released in a calendar year and have to report on the same 24 GHGs with the same GWPs, the province has set stringent emission caps for all facilities as a collective whole. The goal of these cumulative totals is to reduce emissions by 53% relative to 2005 levels and eventually reach net-zero emissions by 2050.
Subsection 4(1), "Compliance period and emission caps", of Nova Scotia's Greenhouse Gas Emissions Regulations
From Nova Scotia's GHG reporting regulation, it is unclear exactly how the emission caps would be distributed across all facilities in the province (it only states that a maximum may be allocated to an individual facility by the Minister). The burden seems to fall on the facility owner, whose responsibility it is to "coordinate with other facility owners to reduce emissions and implement emissions-reduction measures".
The province also provides guidelines on applying to the Minister for new transmission incentives that can be applied toward the emission cap for a given compliance period. The facility owner has to demonstrate they have invested (or will invest) in new transmission capacity that increases the facility's ability to move electrical power generated in Nova Scotia by renewable energy (called "sources of low-emissions electricity"). [See the table in subsection 7(3) for information on the amount of a new transmission incentive.]
GHG reports are due on March 31st and must include an assessment by an independent, accredited verifier in accordance with the ISO 14064-3 standard.
Electricity generators and large industrial emitters (annual emissions over 50,000 tons of CO2e) should also keep in mind Nova Scotia's Output-Based Pricing System (OBPS) for Industry, which replaced the province's cap-and-trade program in 2023. The system sets facility-level emissions intensity standards similar to New Brunswick's performance standards (described above); if the facility emits above its annual limit, it must make up those emissions with performance credits or fund credits. Facilities with emissions above the 10,000-ton threshold may opt into the program to avoid being subject to the Canada federal fuel charge.
Ontario: Greenhouse Gas Emissions Requirements under Reg 390/18
Ontario’s Greenhouse Gas Emissions: Quantification, Reporting, and Verification regulation under the Environmental Protection Act establishes the reporting requirements regulating industrial facilities in the province. Its threshold for greenhouse gas reporting is the same as the federal GHGRP—10,000 tons of CO2e emissions released in a calendar year—but also includes two other kinds of emitters: those that import any amount of Megawatt hours of electricity per year and those covered by the Emissions Performance Standards (EPS) program.
Facilities are required to register for Emissions Performance Standards if they meet the following criteria:
- The facility owner/operator was required to report the facility's GHG emissions for 2014 or any subsequent year
- The facility reported 50,000 tons of CO2e emissions or more in one or more reporting years, from 2014 onward
- The primary activity at the facility is an industrial activity listed in paragraphs 1 to 38 of Schedule 2 of the regulation
Additionally, brand new facilities expected to emit above the 10,000-ton threshold (within three years following the year of first production) and existing facilities that engage in Schedule 2 activities and either reported emissions above the threshold at least once after reporting year 2014 or are expected to exceed the threshold after substantial completion of an eligible modification are allowed to opt into the program.
Facilities registered for the EPS program must adhere to more stringent regulations, such as meeting the total annual emissions limits and having their reports verified by an independent, third-party, accredited verification body by September 1st. Why a facility below the 50,000-ton threshold would voluntarily submit to these additional requirements is simple: only those registered to the EPS program are eligible for exemption from the federal fuel charge.
Regardless of participation in the EPS program, GHG emission reports in Ontario are due June 1st of each year via the ECCC's Single Window System and must follow all provincial guidelines, especially those concerning the standard quantification methodologies for each of the 27 reportable activities (see the reporting guide).
Quebec: Mandatory GHG and Contaminant Reporting
Like BC, Quebec has some of the strictest GHG reporting requirements in the country: its Regulation Respecting Mandatory Reporting of Certain Emissions of Contaminants into the Atmosphere (Q-2, r. 15) not only applies the usual 10,000-ton threshold for GHGs (substances in Schedule A.1), but also establishes specific reporting thresholds for individual substances and substance groups responsible for toxic pollution, acid rain, and smog (substances in Schedule A).
For Schedule A substances (e.g. Sulphur dioxide), facilities in Quebec need to report the quantity emitted of each contaminant, the sources of the emissions, the volume of production, the quantity of fuel and raw materials inputted, and the calculation method used (CEMS, mass balance, modeling, etc.).
Reporting of Schedule A.1 substances is done similarly to the way it is done at the federal level, but a handful of idiosyncrasies exist. The most salient ones may be the 200-litre reporting threshold for fuel distributors, the obligation to report if the facility is engaged in the capture, storage, reuse, or elimination of GHGs or the transfer or receipt of emissions from other operators, and the fact that a facility needs to remain below the threshold for four consecutive years before it can claim an exemption.
Make sure to go over all of section 6.2 of Quebec's GHG reporting regulation Q-2, r.15 carefully for a complete list of everything that must be included in the report. The calculation protocols (equations, tables, methods, etc.) listed in Schedule A.2, which cover 35 different activities (and therefore comprise the majority of the regulation), are equally important to read.
Reports are due on June 1st through the Quebec Air Emissions Inventory (IQEA) online platform (see step-by-step submission instructions, in French). Emitters covered by the cap-and-trade system for GHG emission allowances must also submit a verification report carried out in accordance with the ISO 14064-3 standard by an ISO accredited organization.
The Right Software for Canadian GHG Emissions Reporting Online
As we saw above, the differences between the federal GHGRP and any given province's own regulations can be substantial. They can have a huge impact when it comes to whether you are required to report and, if you are, how much work needs to go into the report's preparation. It's simply incorrect to assume that your federal reporting obligations are an accurate reflection of your provincial responsibilities.
However, some degree of overlap that saves you time at the reporting stage is still possible with the help of a software that centralizes all your production data. ERA's Air Emissions Management Software tracks your GHG emissions across your operations and facilities and determines reporting thresholds for you according to the latest regulations, enabling you to expedite the creation of reports by pulling from complete, up-to-date data to populate any report from a whole suite of built-in options.
For example, if your facility is located in Alberta, you can easily compare your total direct emissions (calculated according to standard GWP values) against the shared 10,000-ton threshold while simultaneously measuring biomass emissions for reporting as a separate category. We are also happy to work with you to incorporate AQMs into your measurement and calculation procedures, as required.
Moreover, we already have experience creating ready-to-upload e-reports for the ECCC's SWIM platform, as this is a feature we implemented into our NPRI Reporting module as recently as RY 2024. Such an addition has drastically cut our clients' data preparation and report submission time, allowing them to focus on more important activities, such as year-round data entry and emissions reduction plans.
Book a meeting with one of our Project Analysts to find out just how easy ERA can make online greenhouse gas emissions reporting for facilities across Canada, no matter the province.
An earlier version of this blog (published in 2011) was originally written by Alex Chamberlain.
This Blog was Co-Authored By:
Comments