Cap-and-Invest third-party emissions verification

In 2022, the Greenhouse Gas Reporting regulation was updated to include a broader group of industries and to align with the requirements of the Cap-and-Invest Program. It was also updated to include an additional quality-assurance mechanism: third-party emissions verification.

Emissions reports submitted to us are reviewed and verified by our staff. Under the updated rule, certain reporters must also contract with a third-party verifier. These independent verifiers will review each entity's annual emissions reports and send us a statement each year indicating whether or not the reports are accurate.

How do I know if my business needs to hire a third-party verifier?

All businesses that are subject to, or are voluntary participants in, the cap-and-invest program are required to have their emissions reports verified by a third-party verifier. However, other businesses reporting emissions under Chapter 173-441 may also be required to do so, depending on their emissions levels:

Threshold for reporting emissions: 10,000 metric tons
Threshold for third-party verification: 25,000 metric tons
Threshold for coverage under cap-and-invest: 25,000 metric tons after accounting for exemptions set in state law.

In addition, any reporter that drops below the 25,000 MT CO₂e threshold must still have its emissions reports verified for the first year.

Introduction to third-party verification for reporters

In October 2023, we held a training covering how to begin the third-party verification process in the Greenhouse Gas Registration Platform, what to expect during the verification process, and how to prepare.

Request the 3PV for Reporters training via email

Additional third-party verification trainings for emissions reporters will be listed here once we schedule them.

For trainings on how to report emissions, see our Emissions page. Refer to the Third-Party Verification Guidelines for more detailed information and instructions on third-party verification.

Forms for reporters and third-party verifiers are currently in development and will be available through the Greenhouse Gas Registration Platform website for registered reporters and verifiers.

Verification tips for reporters

The process of third-party verification takes several months, so we recommend that reporters contact a Washington-certified verification body as soon as possible. At the start of the verification process, reporters will need to submit documentation to us declaring the third-party verification contract and certifying there are no conflicts of interest.

These declaration forms are in development and will be available through the Greenhouse Gas Registration Program website once finalized. Once these forms are available, reporters will be able to submit them through the same Greenhouse Gas Registration Program platform that is used to submit annual emissions reports.

It's important to note that reporters can't use the same verification body for more than six consecutive years, and must wait at least three years before contracting with a previous verification body again.

For a list of Washington-certified verifiers and verification bodies, please email ghgverification@ecy.wa.gov.

A verification team consists of a lead verifier, supporting verifiers, and may include a sector specialist.

Full verification will require a site visit and interviews with key personnel, so reporters should work with their verifiers to ensure compliance.

After reviewing emissions reports, verifiers may submit a list of correctable errors. These issues must be resolved and a corrected report submitted by the deadline to receive a positive verification statement.

Verifiers will treat all data as confidential business information. However, they cannot provide advice. Reporters should contact GHGReporting@ecy.wa.gov with any questions about third-party verification requirements or process.

Verifiers may ask for other types of information, but being able to provide the following documentation can help the verification process go smoothly:

Greenhouse gas monitoring and reporting plan – Verifiers will ask for documentation of overall procedures as well as details about:
- Process and methods to collect emissions data
- Quality assurance, maintenance, calibration and repair of instruments used to provide reported data
- Raw data used to calculate emissions
Records pertaining to emissions calculations, including:
- Documentation of fuel and electricity transactions
- Documentation of instrument maintenance
- Greenhouse gas collection data
- Previous emissions reports and supporting documentation
  - Your verifier will have access to all reports submitted to us via the WEDGE application
- Note: it's required that reporters retain this information for at least 10 years.

Resources for verifiers

Both verification bodies and individual verifiers must meet certain requirements to be certified in Washington, including:

Active accreditation in California
Demonstration of sufficient knowledge of Washington's regulations, Chapter 173-441 WAC and Chapter 173-446 WAC

Individual verifiers must also complete the Washington third-party verification training. Both lead verifier and specialized sector certification require demonstration of additional work experience and corresponding certification.

All eligible verifiers and verification bodies are invited to register in Washington using our Greenhouse Gas Registration Program application.

Past trainings

To request a recording of a training, or to be added to an email list for announcements of upcoming trainings, please email GHGVerification@ecy.wa.gov.

Date	Event
August 2023	Third-Party Verification Manual released
August 2023	Greenhouse Gas Registration Program user manual for verifiers released
Sept. 13, 2023	Third-Party Individual Verifier Certification Training This training covers Washington’s general verification requirements.
Sept.20, 2023	Introduction to the Greenhouse Gas Registration Program for Verifiers Training This training introduces the usage of the online Greenhouse Gas Registration Program for initiating a third-party verification process, reviewing greenhouse gas emission reports, and entering a verification statement.
Sept. 27, 2023	Third-Party Individual Verifier – Process Specialist Certification Training This training covers Washington’s verification requirements for process emissions.
Oct. 25, 2023	Third-Party Individual Verifier – Transaction Specialist Certification Training This training covers Washington’s verification requirements for transaction emissions.
Nov. 8, 2023	Third-Party Individual Verifier – Oil and Gas Specialist Certification Training This training covers Washington’s verification requirements for oil and gas emissions.

Forms for reporters and third-party verifiers are currently in development and will be available through the Greenhouse Gas Registration Program website for registered reporters and verifiers.

Conflict of interest

The purpose of the third-party verification requirement is to ensure submitted emissions reports are accurate. To serve this purpose, it is important that verifiers be impartial when reviewing reporter submissions. This requires avoiding any potential conflict of interest as outlined in Chapter 173-441-085 (7)(c)

Conflict of interest can be:

Low: verification relationship will be approved
Medium: verification may proceed with an approved mitigation plan
High: verification relationship will not be approved.

Contact information

Katie Kaku
Third Party Verifier Program Specialist
GHGReporting@ecy.wa.gov
360-706-3902

Climate Commitment Act Questions

CCAQuestions@ecy.wa.gov