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Verification for Clean Air Rule reports

In March 2018, Thurston County Superior Court ruled that parts of the Clean Air Rule are invalid. The Superior Court's ruling prevents us from implementing the Clean Air Rule regulations that cap and gradually reduce major sources of carbon pollution. This means that compliance with the rule currently is suspended. On May 14, 2018 we published a media release and filed an appeal with the Washington State Supreme Court.

Under a separate Ecology rule, facilities covered by the Clean Air Rule still are required to report their emissions for the Greenhouse Gas Reporting program.

Businesses covered by the Clean Air Rule need to have their compliance and greenhouse gas reports verified. Verification needs to be done by an approved third party. We will train, approve, and provide a list of third party verifiers. Verifiers are responsible for submitting verification reports to Ecology.

2017 Greenhouse gas emissions report verification

Organizations reporting greenhouse gas emissions data for 2017 that are covered by the Clean Air Rule need to use a verifier from the list of verifiers and verification bodies approved for greenhouse gas reporting. This list does not currently include transactions specialists. Transactions specialist training is scheduled for Dec. 2017. We will update the list to include transactions specialist verifiers in early 2018. For more information see the Greenhouse Gas Reporting Verification Guidance for Facility Operators and  Greenhouse Gas Emissions Report Verification Manual.

Three-year-compliance report verification

Compliance reports also need to be verified by an approved verifier. A list of companies and individual verifiers for three-year compliance reports is not yet available. We will notify regulated organizations when the list is published.

Become a verifier

Individual verifiers and verification companies interested in becoming an approved third party verifier can submit an application.

Qualified individuals will be invited to attend our mandatory training. The first training is offered Sept. 14, 2017. Those who successfully complete the training course and meet all other requirements will be approved to verify greenhouse gas reports for facilities covered by the Clean Air Rule. A separate training for compliance report verification will be offered at a later date.

Individuals accredited as a transactions specialist by California's ARB must attend additional training to become certified as a transactions specialist by Ecology. Information about this training will be posted on our website in the future.

Criteria for verification companies

  • Active accreditation as a third party verifier under at least one of the following greenhouse gas programs:
  • Employ at least two lead verifiers certified by Ecology.
  • Maintain at least $4 million professional liability insurance.
  • Provide proof of procedures or policies that support ongoing verification training for staff.
  • Disclose all judicial proceedings, enforcement, or administrative actions filed against the organization within the last five years.
  • Provide proof of policies and mechanisms that prevent conflicts of interest and identify and resolve potential conflicts of interest.

Criteria for all individual verifiers

  • Complete Ecology training and show knowledge of Washington's greenhouse gas and Clean Air Rule reporting protocols.
  • Be employed or subcontracted by an Ecology approved verification company.
  • Provide proof of accreditation in California's ARB Mandatory Reporting of Greenhouse Gas Emissions program. Or, if you are affiliated with a verification company accredited by ANSI provide the additional criteria listed below.

Additional criteria for individual verifiers affiliated with a company accredited by ANSI

Verifier

  • Bachelor's degree or equivalent in science, technology, business, statistics, mathematics, environmental policy, economics, or financial auditing; or work experience or personal development activities that provide the applicant with the communication, technical, and analytical skills necessary to conduct verification.
  • At least two years of full-time work experience in emissions data management, emissions technology, emissions inventories, environmental auditing, or other technical skills necessary to conduct verification.

Lead Verifier

  • Meets criteria for verifier.
  • At least four years of work experience as a project manager or lead, of which two years may be graduate level work in the development of greenhouse gas or other air emissions inventories or work as a lead environmental data or financial auditor in the private sector.

Specialized Sector Verifier

  • Meets criteria for verifier.
  • At least two years of professional experience in the sector.
  • Affiliated with a verification company accredited in the same sector.