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Enterprise Greenhouse Gas Reporting

Industry challenge Organizations face many challenges in today’s rapidly

With the enacting of the U.S. Environmental Protection evolving carbon-regulatory landscape, including:
Agency (EPA)’s Mandatory Reporting of Greenhouse
• Understanding the new mandates and how to
Gases (GHG) Rule (MRR), or 40 CFR Part 98, emissions-
implement the same
intensive private and public facilities will be required to
• Developing a GHG governance model suited to your
report their 2010 Scope 1 emissions by March 31, 2011,
organization, including reliable controls, appropriate
and every year thereafter. Under MRR, suppliers of fossil
protocols, and efficient and effective processes
fuels or industrial GHGs, manufacturers of vehicles and
• Integrating your GHG reduction and adaptation
engines, and facilities that emit 25,000 metric tons or
initiatives with GHG reporting obligations
more per year of GHG emissions are required to submit
• Leveraging information technology (IT) solutions
annual reports to EPA. As part of their compliance
to enable greater automation, accuracy, and
requirement, covered entities must also provide the
transparency, while adding capabilities, such as
EPA with monitoring plans, detailed quality assurance
scenario modeling and forecasting, streamlining
documentation, and signed certification statements.
data management, and minimizing the use of
spreadsheets and other manual processes
All facilities covered by the Regional Greenhouse Gas
• Bolstering in-house knowledge and preparedness around
Initiative (RGGI) are required to monitor and report carbon
accounting implications of carbon-regulatory obligations
emissions to demonstrate compliance with the RGGI
• Preparing for potential carbon-regulatory legislation
carbon reduction program.
requiring the holding of tradable emissions permits

Reporting of greenhouse gases by major sources is required

Why act now?
by the California Global Warming Solutions Act (AB 32).
Looming reporting deadlines:
• March 2011 under EPA MRR
In addition, states such as Oregon, Washington, New
Mexico, Florida, and North Carolina require mandatory
Work involved includes:
reporting of GHG emissions.
• Quantify and understand emissions portfolios and
baseline GHG emissions
While compliance is often a significant driver of
• Develop processes, systems, and resources to support
strengthening controls and processes around GHGs, carbon
the GHG reporting and accounting requirements
management has entered the purview of leadership, as it
• Institute requisite reporting controls
has strategic, financial, and governance implications.
• Prepare for the possibility of future monetization of carbon
However, successful carbon management requires controls, policies and procedures, and identification,
more than mere compliance. An integrated approach, assessment and prioritization of reporting risks.
supported by detailed governance, controls, and
policies and procedures can inform long-term strategic Reporting governance and controls implementation.
decisions and help align management disclosures, Designed to mitigate risks and gaps discovered in the
statements, and reporting. reporting readiness assessment, this implementation
includes assistance with the development of an entity-level
The Deloitte difference reporting strategy, a governance approach and definitions
Deloitte, together with Deloitte Canada, is a recognized of key roles and responsibilities, documentation of
leader in providing strategy services to the public and reporting policy and procedures, and documentation of a
private sector. The strategies, analytical tools and decision GHG monitoring plan and an emissions inventory strategy.
models offered to clients are informed by capabilities A Quality Assurance (QA)/Quality Control (QC) protocol
in four leading class practices: Consulting, Audit/Risk, will be developed to support self-certification, facility-level
Financial Advisory Services, and Tax. reporting, periodic internal audit review, and entity-level
oversight. Lastly, controls will be designed, implemented,
• A multidisciplinary approach to excellence provides
and tested, including a reporting ‘dry run’ and stress test.
top-tier client services to key industries affected
by sustainability, including energy & resources,
Reporting technology support. Assistance with IT
financial services, consumer & industrial products,
vendor selection, implementation and integration to
telecommunications, media & technology, federal/state
required efficiency in reporting processes and strategic
governments, and health care/life sciences.
planning. This may include assisting with establishing
• The Integrated Carbon Management Framework:
master data management protocols and controls, defining
Drivers Carbon Management Decisions functional requirements, performing a “build versus buy”
analysis, and developing customized reports (e.g., external
SEC Disclosure
compliance, forecasts, risk monitoring).
In Effect for U.S.

EPA Regulation Reporting &
Executive Orders MEASURE
ōHistorical / Baseline Strategy Carbon accounting. Assistance in understanding financial
ōYear to Date
State / Regional
Programs Policies
Controls Capital
statement implications, accounting treatment election, and
Case by Case

ōBalance of Year
Customers /
ōScenario Modeling
valuation of carbon-regulatory obligations. Also includes
IT Infrastructure
Board / Senior Trading/ development of accounting policies and procedures, and
Management Processes Hedging
valuation guidance for carbon offset credits, RECs, and

Legislation other environmental instruments.

Qualifications and experience

• Deloitte Center for Energy Solutions in Washington, D.C.
Sustainability strategy and GHG reporting
and Houston provides a “think tank” for early insight into
Deloitte helped a large U.S. Bank with its sustainability
emerging energy industry/policy trends and a forum for
strategy and GHG reporting. Key benefits included
debate, collaboration, and innovation. The Center provides
development of a sustainability definition and vision
a broad perspective on policy/regulatory, industry and
statement aligned with the company’s overall strategy;
technology opportunities, and challenges to our clients.
prioritized sustainability initiatives based on alignment with
strategy, resource requirements, complexity, and projected
Deloitte capabilities
impact; a road map and performance measurement tools
Deloitte and Deloitte Canada have Carbon Management
with key short-, middle-, and long-term activities designed
Services practices that have demonstrated methodologies
to help the client become a more sustainable enterprise;
and tools that are designed to act as accelerators for
a multitiered governance structure responsible for
implementing carbon strategies, processes and systems for
implementation and performance of sustainability strategy;
organizations. Offerings include:
an organization-wide GHG baseline and a detailed
response to the CDP6. In addition, we assisted the client to
Reporting readiness assessment. A broad precompliance assess the early success of several sustainability initiatives,
assessment of organizational preparedness for GHG including the client’s Global Reporting Initiative reporting
reporting. This assessment includes assistance related to readiness and the provision of a reporting gap analysis
identification of applicable reporting requirements and and recommended actions for a successful release of the
the facilities required to report, a gap analysis of existing bank’s inaugural sustainability report.

Quality assurance/quality control framework Eminence and thought leadership
In anticipation of the regulatory compliance requirement Deloitte has demonstrated leading insight in the
to report GHG emissions under the MRR, Deloitte’s client, sustainability space through a variety of eminence and
a Major electricity generating company, recognized thought leadership publications:
the need for the development of quality assurance
(QA) and quality control (QC) protocols and processes. A Profitable Shade of Green:
Deloitte was engaged for this project. Key benefits Compounding the benefits of carbon
included assisting the client with the identification of management and sustainability measures
relevant subparts of the EPA MRR specific to the client’s
business and operations to determine compliance with
these regulations; development of QA/QC protocols and
processes to address requirements under the EPA MRR; Carbon accounting challenges:
development of self-certification checklist templates Are you ready?
for both operating and internal audit staff; facilitation
of training and knowledge transfer of the QA and QC
protocols and processes to identified client personnel.

Reporting and strategy development Power from Perspective:

Deloitte supported the U.S. Postal Service in report Potential United States Energy Scenarios
development and QA of data source systems. Deloitte also
evaluated reporting software and assess whether metrics
and calculations were appropriate for the client’s purposes.
Deloitte also helped develop a sustainability strategy
that included key metrics and goals that, in disclosure to Creating the Wholly Sustainable
other federal agencies and the general public, would help Enterprise:
demonstrate “sustainability leadership” with operational A Practical Guide to
and performance transparency. Driving Shareholder Value through
Enterprise Sustainability

Clean over Green:

Striking a New Balance

Points of contact
Stephen Engler
Deloitte & Touche LLP
This publication contains general information only and Deloitte is not, by means of this publication, rendering sengler@deloitte.com
accounting, business, financial, investment, legal, tax, or other professional advice or services. This publication +1 973 602 5206
is not a substitute for such professional advice or services, nor should it be used as a basis for any decision or
action that may affect your business. Before making any decision or taking any action that may affect your
business, you should consult a qualified professional advisor. Pat Concessi
Deloitte, its affiliates, and related entities shall not be responsible for any loss sustained by any person Deloitte & Touche LLP (Canada)
who relies on this publication.
As used in this document, “Deloitte” means Deloitte & Touche LLP, which provides audit and risk consulting +1 403 503 1448
services; Deloitte Consulting LLP which provides management consulting services; Deloitte Tax LLP, which
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