In Part 3 of Spirit’s carbon journey, we discuss how our company continues to explore carbon market nuances and offset business emissions/commuting emissions for our team. Recognizing the global nature of climate change, Spirit chose to invest in projects that would safely dispose of some of the highest global warming potential refrigerants still in use internationally while continuing to support an international biochar development program.
In Part 2 of Spirit’s carbon journey, we discuss how our company pivoted to offset Spirit’s business-related travel and total commuting emissions. To better align with industry best practices, Spirit adopted the use of Renewable Energy Certificates (RECs) to offset our electricity consumption rather than carbon offsets. Finally, in addition to the landfill gas capture credits used to offset 2019 and 2020, Spirit purchased offsets for carbon injected concrete and biochar to address Scope 1 and Scope 3 emissions.
TCEQ issued the renewal of the CGP with an effective date of March 5, 2023.
Spirit’s journey to carbon offsets started by looking at our major emissions sources, gathering data from our building management on energy consumption, surveying employees to evaluate commuting emissions, and determining which emissions were most material to our business. Once we had a preliminary handle on the numbers, we evaluated several options for offsetting our emissions before settling on a landfill methane gas capture project for 2019 and 2020.
On December 6, 2022, the EPA published a Supplemental Notice of Proposed Rulemaking in the Federal Register. The proposal is intended to significantly reduce emissions of GHGs and other harmful air pollutants from the Crude Oil and Natural Gas source category and affects 40 CFR Part 60 Subparts OOOOb and OOOOc. The EPA comment period is open until February 13, 2023.
The EPA’s proposed particulate matter NAAQS Reconsideration Rule was published in the Federal Register on January 27, 2023. The EPA is proposing to lower the primary annual PM2.5 NAAQS, and they are requesting comments on the possibility of lowering the daily (24-hour) standard as well.
On December 30, 2022, the US EPA and the USACE finalized the rule establishing the definition of “waters of the United States”. This definition will go into effect 60 days after publication in the Federal Register.
There are many different compliance reporting deadlines in Q1 and Q2 of 2023. Be aware that some of these reporting obligations require careful planning and preparation time. SARA Tier II Reporting, Annual Waste Reporting, TRI Reporting, and Annual Training obligations should all be evaluated in January to determine which items may be due in Q1 and Q2.
The TCEQ recently released a notice with important discussion points regarding the MECT and HECT Programs. Allowance trades for 2022 compliance under these programs are due by January 30, 2023.
Facilities with an active NOI for the MSGP TXR050000 must conduct annual NEL sampling for stormwater discharges by December 31, 2022.