2006 - 2007 CALIFORNIA CLIMATE ACTION REGISTRY GREENHOUSE GAS INVENTORIES VERIFICATION REPORT Final (revised) 5528-B Hempstead Way Springfield, VA 22151 703-813-6700 telephone 703-813-6729 facsimile 3622 Lyckan Parkway Suite 2002 Durham, NC 27707 919-493-3144 telephone 919-493-3182 facsimile Prepared for the: San Lorenzo Valley Water District 13060 Highway 9 Boulder Creek, CA 95006-9119 Prepared by: Stephen M. Roe Juan Maldonado Holly C. Lindquist James H. Wilson E.H. Pechan & Associates, Inc. December 15, 2008 PECHAN December 2008 CONTENTS Page ACRONYMS AND ABBREVIATIONS ........................................................................................ 1 VERIFICATION ACTIVITIES FOR THE 2006 & 2007 REPORTING YEARS ......................... 2 SCOPE OF THE VERIFICATION PROCESS ....................................................................... 2 STANDARD USED TO CALCULATE EMISSIONS ........................................................... 2 SCOPE OF VERIFICATION ACTIVITIES ........................................................................... 2 1. List of Identified Emission Sources and Organizational Boundaries....................... 3 1.1. Identified Sources ............................................................................................. 3 1.2. Organizational Boundaries ............................................................................... 4 2. Sampling Techniques and Risk Assessment Methods ............................................. 4 3. Comparison of SLVWD and Pechan Emission Estimates ....................................... 6 3.1. Indirect Emissions ............................................................................................ 6 3.2. Direct Emissions – Stationary Combustion ...................................................... 6 3.3. Direct Emissions – Fugitive Emissions ............................................................ 7 3.4 Direct Emissions – Mobile Source Combustion............................................. 10 3.5 Process Direct Emissions................................................................................ 11 3.6 Fugitive Direct Emissions .............................................................................. 11 3.7 De Minimis Sources ....................................................................................... 12 3.8 Material Misstatements................................................................................... 12 3.9 Immaterial Misstatements............................................................................... 12 3.10 General Evaluation of Compliance................................................................. 12 3.11 Verification Conclusion .................................................................................. 13 REFERENCES ............................................................................................................................ 14 TABLES Table 1. Table 2. Table 3. Table 4. Table 5. Table 6. Final Site Visits Conducted as Part of the CY 2006-2007 GHG Verification………….......…3 SLVWD’s CARROT Facilities for 2006 – 2007………………………..………………4 Assessment of Reporting Risk…………………………………………………..………5 Comparison of SLVWD’s 2006 Emission Estimates and Pechan’s Estimates…………8 Comparison of SLVWD’s 2007 Emission Estimates and Pechan’s Estimates ……...…9 Differences between SLVWD and Pechan Mobile Source Activity Data……………..11 iii 2006-2007 California Climate Action Registry Greenhouse Gas Inventories Verification Report PECHAN December 2008 ACRONYMS AND ABBREVIATIONS BTU CARROT CH4 CO2 CO2e CY EF GHG GRP HFC IPCC kWh LGO MMBTU N2O PFC PG&E Registry SF6 SLVWD t WW WWTP Final British Thermal Unit Climate Action Registry Reporting On-line Tool methane carbon dioxide carbon dioxide equivalents calendar year emission factor greenhouse gas The Registry’s General Reporting Protocol hydrofluorocarbon Intergovernmental Panel on Climate Change kilowatt-hour The Registry’s Local Government Operations Protocol million British Thermal Units nitrous oxide perfluorocarbon Pacific Gas & Electric The California Climate Action Registry sulfur hexafluoride San Lorenzo Valley Water District metric tons wastewater wastewater treatment plant 1 2006-2007 California Climate Action Registry Greenhouse Gas Inventories Verification Report PECHAN December 2008 VERIFICATION ACTIVITIES FOR THE 2006 & 2007 REPORTING YEARS SCOPE OF THE VERIFICATION PROCESS The San Lorenzo Valley Water District (SLVWD) contracted with E.H. Pechan & Associates, Inc. (Pechan) to verify its greenhouse gas (GHG) emissions reported to the California Climate Action Registry (the Registry) for the years 2006 and 2007. Calendar year 2006 was selected as the base year for reporting to the Registry. These are the first years of GHG reporting by SLVWD to the Registry, and include accounting for all six gases: carbon dioxide (CO2); methane (CH4); nitrous oxide (N2O); hydrofluorocarbons (HFCs); perfluorocarbons (PFCs); and sulfur hexafluoride (SF6). All of SLVWD’s GHG sources are located in California and emission estimates have been submitted into the Registry’s Climate Action Registry Reporting On-line Tool (CARROT). SLVWD selected reporting boundaries as management control - operation criteria. The San Lorenzo Valley Water District (SLVWD) is an independent special district supplying water to approximately 18,000 people on the Central Coast. SLVWD utilizes both surface water and ground water sources. SLVWD also owns and operates a wastewater treatment facility, serving about 50 houses. STANDARD USED TO CALCULATE EMISSIONS For its combustion, process and electricity consumption GHG sources, SLVWD estimated its emissions based on the methods outlined in the Registry’s General Reporting Protocol (GRP) (CCAR, 2008a). SCOPE OF VERIFICATION ACTIVITIES The scope of this verification of calendar year (CY) 2006 and 2007 emissions covers all sources of all six GHGs recognized by the Registry. The coverage includes all GHG sources over which SLVWD maintains operational control. Verification activities for CY 2006-2007 included the following: Review of SLVWD’s CARROT submittal and comparison of the identified emission sources to those expected by Pechan to emit GHGs; Site visits to several SLVWD facilities to assess the coverage of GHG sources and gather information underlying the 2006-2007 reporting (see Table 1 below); Comparison of the underlying activity data used by SLVWD to other sources of data [including Pacific Gas & Electric (PG&E); other internal SLVWD data sources]; and Comparison of SLVWD-estimated GHG emission estimates to those developed by Pechan. The site visits were selected and conducted on the basis of their emissions potential in terms of contribution to SLVWD’s total entity-level emissions. SLVWD’s CARROT reporting aggregated GHG sources into 4 facilities: Final 2 2006-2007 California Climate Action Registry Greenhouse Gas Inventories Verification Report PECHAN December 2008 ADMIN - includes office space at 13060 Highway 9 in Boulder Creek and associated vehicle; OPS/DISTRIBUTION - includes a building at 13057 Highway 9 in Boulder Creek, pumping stations, water storage, and associated vehicles and nonroad equipment; OPS/SUPPLY & TREATMENT - includes well pumps, booster pumps, potable water treatment facility, and the associated vehicles and nonroad equipment; and WASTEWATER – covers the Bear Creek wastewater treatment plant (WWTP) and associated wastewater (WW) lift pump. As shown in Table 1, Pechan’s site visits covered at least one GHG source in each of the reported “CARROT facilities” described in Section 1 below. However, each of the individual assets operated by SLVWD that consume energy or otherwise emit GHGs were not visited. Table 1. Site Visits Conducted as Part of the CY 2006-2007 GHG Verification Site Administrative Building (13060 Highway 9) Operations Building Bear Creek WWTP Lyon Water Treatment Plant Olympia Wells #2 and #3 GHG Emission Sources Electricity consumption, gasoline vehicle, vehicle refrigerants Electricity consumption, propane combustion (generator), onroad and nonroad diesel and gasoline combustion, vehicle refrigerants Electricity consumption, process N2O Electricity consumption, diesel combustion (generator) Electricity consumption In addition to the sources identified and initially reported by SLVWD, Pechan also identified the following GHG sources: natural gas combustion in three buildings; vehicle air conditioners; and nitrous oxide emissions at the Bear Creek WWTP. These sources are addressed under Section 3 below. Pechan verified that stationary air conditioning systems were using R-22 refrigerant, not newer hydrofluorocarbon (HFC) refrigerants that would need to be reported to CARROT. Pechan verified with SLVWD that no electrical equipment were owned (e.g. switchgear, circuit breakers) that could contain components using SF6 as an insulator. Pechan verified with SLVWD that no fire suppression systems using GHGs, such as PFCs, were in use.1 1. List of Identified Emission Sources and Organizational Boundaries 1.1. Identified Sources Table 2 provides a summary of indirect and direct sources identified by SLVWD as reported to the Registry’s on-line reporting tool, CARROT, for the 2006 and 2007 reporting years. Hereafter, we refer to these as “CARROT facilities” to distinguish them from either: actual sites or buildings that SLVWD owns or operates; or individual sources of GHGs (e.g., a natural gas 1 Personal communication between Rick Rogers, SLVWD, Director of Operations, and S. Roe, Pechan. Final 3 2006-2007 California Climate Action Registry Greenhouse Gas Inventories Verification Report PECHAN December 2008 furnace, emergency generator). Reporting risk assessment methods and sampling techniques for each of the CARROT facilities are described in Section 2. Table 2. SLVWD’s CARROT Facilities for 2006 - 2007 Source Type Indirect Direct CARROT Facility 2006 tCO2e 2006 % of Total 2007 tCO2e 7.24 87.67 237.14 7.23 3.90 99.39 26.85 1.02 470.4 1.5% 18.6% 50.4% 1.5% 0.8% 21.1% 5.7% 0.2% 100.0% 7.70 96.30 321.78 5.72 3.51 110.92 23.53 0.94 570.4 Admin OPS/Distribution OPS/Supply & Treatment Wastewater Admin OPS/Distribution OPS/Supply & Treatment Wastewater Total 2007 % of Total 1.3% 16.9% 56.4% 1.0% 0.6% 19.4% 4.1% 0.2% 100.0% SLVWD also generates solar electrical power to offset some of its electrical consumption. Excess power is sold back to PG&E. Any additional power put back on the electrical grid is not captured within SLVWD’s reporting, since it should be captured within PG&E’s delivered electricity metric (which SLVWD uses to estimate its indirect emissions). 1.2. Organizational Boundaries SLVWD based its organizational boundaries on management control using the operational criteria outlined in the GRP (CCAR, 2008a). SLVWD demonstrated that it has operational control over each of the sources identified in its CARROT reporting (e.g. third-party contractors are not used to operate any of its facilities). 2. Sampling Techniques and Risk Assessment Methods As shown in Table 2, the primary contributors to 2006 and 2007 GHG emissions were indirect emissions from electricity consumption and direct emissions from combustion of fuels. Based on the reported 2006 emissions data, Pechan performed an assessment of reporting risk (i.e. risk of reporting a material misstatement of emissions at the entity-level). Table 3 provides a summary of this assessment. The data include the reported CY2006 GHG emissions for each CARROT facility and source, and their contribution to the SLVWD 2006 total. Final 4 2006-2007 California Climate Action Registry Greenhouse Gas Inventories Verification Report PECHAN December 2008 Table 3. Assessment of Reporting Risk NOTE: emissions of N2O and CH4 in this table listed without emission estimates are not necessarily zero; these were listed in the CARROT report as 0.00 metric tons, however the results could have just rounded to 0.00 before application of the global warming potential. In any case, these sources would not have contributed significantly to the entity total. Emissions above only include those identified in the initial SLVWD CARROT reporting. Additional sources identified by Pechan are not included. Final 5 2006-2007 California Climate Action Registry Greenhouse Gas Inventories Verification Report PECHAN December 2008 The reported emissions data are followed by a factor (potential deviation) that represents Pechan’s assessment of the overall uncertainty in the emissions estimate based on both the emission estimation method (e.g. emission factor) and the activity data (e.g. kilowatt-hours of electricity). These estimates of uncertainty are based on Pechan’s professional judgment of the quality in both the emission factor/other emission estimation method used and the activity data used to estimate emissions. The results indicate that for both the reported and projected emission estimates, indirect emissions for electricity consumption (particularly for groundwater wells and booster pumps) and vehicle fleet emissions are the primary contributors to entity-level emissions. Hence, Pechan focused attention on these sources during this CY2006-2007 verification. 3. Comparison of SLVWD and Pechan Emission Estimates A comparison of the SLVWD’s 2006 and 2007 GHG emission estimates to those developed by Pechan is provided in Tables 4 and 5 below. From Table 4, the difference of total emissions excluding de minimis sources at the entity-level for CY2006 is -13.7 tCO2e or -2.8 percent. Much of this difference stems from a different approach in estimating liquid petroleum gas (LPG) consumption by generators and immaterial discrepancies found in fuel usage activity data. In Table 5 covering CY2007, the difference was less than 1 tCO2e and less than 1 percent. In the subsections that follow, details of the assessment of each source (CARROT facility) are provided. 3.1. Indirect Emissions Indirect emissions are limited to those associated with electricity consumption. Electricity consumption was reported under all four CARROT facilities (Admin, OPS/Distribution, OPS/Supply and Treatment, and Wastewater). Pechan obtained 2006 and 2007 billing data by meter from the electricity provider PG&E (Roderos, 2008). For 2006, Pechan’s estimate for the total indirect emissions associated with electricity consumption was 339 metric tons, the same as SLVWD’s estimate. For 2007, Pechan’s estimate for the total indirect emissions associated with electricity consumption was 432 metric tons, the same as SLVWD’s estimate. 3.2. Direct Emissions – Stationary Combustion Direct stationary emissions in Tables 4 and 5 represent department aggregate amounts of diesel, gasoline, liquid petroleum gas, and natural gas fuel combustion. A description of each fuel type follows below. Diesel Combustion Stationary diesel combustion was associated with the operation of generators. For 2006 and 2007, SLVWD did not have a direct means of measuring the volume of diesel dispensed to each generator. In order to estimate activity data for this source, Pechan adopted the SLVWD method of estimating diesel consumption from MBRAPCD reports for generators GT-670, GT-740, GE00290. Pechan recommends direct measurements of fuel dispensed to generators since values on Final 6 2006-2007 California Climate Action Registry Greenhouse Gas Inventories Verification Report PECHAN December 2008 MBRAPCD reports do not represent calendar year (January to December) consumption. Additional diesel combustion was identified in GASFY2 as “can” diesel and was attributed to generator GE-00971. Pechan agrees with the choice of emission factors selected from the GRP (CCAR, 2008a) by SLVWD. 3.3. Direct Emissions – Fugitive Emissions Because fugitive emissions from refrigerant losses are typically negligible when compared with total entity emissions, the GRP prescribes the use of a screening method that helps determine whether fugitive emissions are insignificant or warrant a more comprehensive review. The screening method assumes a refrigerant charge of 1 kg of HFC-134a for large vehicles and 0.5 kg of the same compound for small vehicles. The refrigerant loss rate for both vehicle types is assumed to be 35%. In 2006, SLVWD operated 19 vehicles, of which 17 were estimated by Pechan to be equipped with air conditioning units. Of these 17 vehicles, 2 were small and 15 were large in size. In 2007, SLVWD operated 21 vehicles, of which 18 were estimated to be equipped with air conditioning units. Of these 17 vehicles, 2 were small and 16 were large in size. The screening determined that direct fugitive emissions from vehicle air conditioning units were not significant, and therefore, could be categorized as de minimis emissions. Gasoline Combustion GASFY identifies gasoline used for fueling stationary equipment (e.g. chain saws, air compressors) as “can” gasoline. No issues were found in SLVWD’s choice of emission factors from the GRP (CCAR, 2008a). Liquid Petroleum Gas (LPG) Combustion Stationary LPG combustion was associated with the operation of generators. According to the GRP (CCAR, 2008a), the preferred method to determine annual consumption of fuels involves having fuel inventory data for the beginning and the end of the year in addition to individual purchases within the year (Equation III.8a). Unfortunately, SLVWD had no inventory information. In lieu of beginning and end inventory values, SLVWD assumed these values to be equivalent to the closest LPG purchase transactions to January 1st, and December 31st of each reporting year. For that reason, and in order to avoid double-counting, Pechan opted to include only those transactions within a reporting year. To reduce uncertainty associated with these sources, Pechan recommends maintaining beginning and end of year inventory records. This difference in approach accounted for the difference in direct stationary emissions totals in Tables 4 and 5. 2 GASFY is a fuel consumption summary spreadsheet maintained by SLVWD’s accounting department. Final 7 2006-2007 California Climate Action Registry Greenhouse Gas Inventories Verification Report PECHAN December 2008 Table 4. Comparison of SLVWD’s 2006 Emission Estimates and Pechan’s Estimates 2006 CO2e Emissions (metric tons) SLVWD Estimate Indirect Emissions Admin (electricity) 7.2 OPS/Distribution (electricity) 87.7 OPS/Supply & Treatment (electricity) 237.1 Wastewater (electricity) 7.2 Indirect Subtotal 339.2 Stationary Direct Emissions Admin (natural gas) 1.0 OPS/Distribution 6.7 OPS/Supply & Treatment 4.6 Wastewater (Generator) 0.7 Mobile Direct Emissions Admin 2.9 OPS/Distribution 93.1 OPS/Supply & Treatment 22.2 Process Direct Emissions Wastewater (Bear Creek Septic System) 0.3 Fugitive Direct Emissions Vehicle Fleet – Fugitive A/C Refrigerants 0.0 Direct Subtotal 131.5 de minimis emissions Booster pumps OPS/Dist 0.3 Building ADMIN 0.0 Groundwater wells, buildings SUP/TR 0.7 Vehicle Fleet ADMIN 0.0 Generator – Admin 0.3 Generator OPS/Dist 0.0 Generators – Supply & Treatment 0.0 de minimis Subtotal 1.3 Totals 472.0 Source (CARROT Facility ID) Pechan Estimate Difference 7.2 87.7 237.1 7.2 339.2 0 0 0 0 0 1.0 6.1 4.6 0.8 0 0.6 0 -0.1 2.4 101.7 21.0 0.5 -8.6 1.2 0.3 0 7.3 145.2 -7.3 -13.7 0.3 0.0 0.7 0.1 0.6 0.0 0.0 1.7 486.1 0 0 0 -0.1 -0.3 0 0 -0.4 -14.1 Totals (excluding de minimis sources) 470.7 484.4 Difference Between SLVWD and Pechan Estimates = -13.7 -2.8% NOTE: Totals may not add exactly due to rounding. Some totals and subtotal differ from CARROT report due to adjusted emission categorization. Final 8 2006-2007 California Climate Action Registry Greenhouse Gas Inventories Verification Report PECHAN December 2008 Table 5. Comparison of SLVWD’s 2007 Emission Estimates and Pechan’s Estimates 2007 CO2e Emissions (metric tons) SLVWD Estimate Indirect Emissions Admin (electricity) 7.7 OPS/Distribution (electricity) 96.3 OPS/Supply & Treatment (electricity) 321.8 Wastewater (electricity) 5.7 Indirect Subtotal 431.5 Stationary Direct Emissions Admin (natural gas) 2.3 OPS/Distribution 4.3 OPS/Supply & Treatment 3.0 Wastewater (Generator) 0.6 Mobile Direct Emissions Admin 1.2 OPS/Distribution 106.6 OPS/Supply & Treatment 20.5 Process Direct Emissions Wastewater (Bear Creek Septic System) 0.3 Fugitive Direct Emissions 0.0 Vehicle Fleet – Fugitive A/C Refrigerants Direct Subtotal 138.8 de minimis emissions Booster pumps, buildings – OPS/Dist 0.3 Building - ADMIN 0.0 Groundwater wells, buildings - supply 0.9 Wastewater treatment plant 0.0 Vehicle Fleet-ADMIN 0.0 Vehicle Fleet-SUP/TRTMT 0.0 Generator – Admin 0.3 Generators – OPS/Distribution 1.8 Generators – Supply & Treatment 0.0 Generator – WSTWTRa 1.8 de minimis Subtotal 5.1 Totals 574.2 Source (CARROT Facility ID) Pechan Estimate Difference 7.7 96.3 321.8 5.9 431.7 0.0 0.0 0.0 -0.2 -0.2 2.3 4.3 4.5 0.8 0.0 0.0 -1.5 -0.2 1.1 98.3 18.6 0.1 8.3 1.9 0.3 0.0 7.7 137.9 -7.7 0.9 0.3 0.0 0.9 0.0 0.1 0.0 0.0 0.7 0.0 0.0 2.0 570.5 0.0 0.0 0.0 0.0 -0.1 0.0 0.3 1.1 0.0 1.8 3.1 3.8 569.6 0.7 Difference Between SLVWD and Pechan Estimates = 0.1% Totals (excluding de minimis sources) 570.3 NOTE: Totals may not add exactly due to rounding. Some totals and subtotals differ from CARROT report due to adjusted emission categorization. a These are just the CH4 and N2O emissions for the wastewater treatment plant generators. Pechan identified an error in the calculation of these leading to a Pechan estimate of less than 0.1 tCO2e for CH4 and N2O. Final 9 2006-2007 California Climate Action Registry Greenhouse Gas Inventories Verification Report PECHAN December 2008 Natural Gas Combustion Pechan estimated these emissions to be 5.9 metric tons in 2006 and 6.6 metric tons in 2007 based on billing data provided by PG&E (Roderos, 2008). These totals matched SLVWD’s emissions estimates. Additionally, SLVWD split this total by account number to reflect natural gas combustion emissions by department (administration and operations/distribution). 3.4 Direct Emissions – Mobile Source Combustion Direct mobile emissions in Tables 4 and 5 represent department aggregate amounts of diesel, gasoline, and liquid petroleum gas fuel combustion. A description of each fuel type follows below. Gasoline & Diesel Combustion The District has accounts with three local gas stations. According to SLVWD, when a driver buys fuel, he uses the District’s account number to charge the fuel (one of the stations issues the District a Quikstop credit card for each driver; the other two stations, Ben Lomond Gas and Boulder Creek American Gas, have District charge accounts that the drivers use). When gas is charged to the District, these gas stations will pump gas only into District vehicles. When the drivers get the charge receipts, the receipts are stamped with a red District stamp, where the driver writes his name, employee number and truck number. The drivers turn in their receipts every day. The Accounting Department records the fuel used by each truck and then forwards the receipts to Accounts Payable. Pechan conducted a verification of the activity data associated with gasoline and diesel purchase transactions. Due to the large number of transactions consisting of individual fuel purchases per day and per vehicle, Pechan sampled 20% of all transactions according to the guidelines of General Verification Protocol, Section 3.4 (CCAR, 2008b). Complete sets of 2006 and 2007 records for vehicles U155, U311, U339, and D650 were selected because they had the largest fuel consumption values and were representative of both gasoline and diesel fueled vehicles. Pechan’s analysis of the activity data is shown in Table 6. All fuel consumption was adjusted to reflect the findings shown in Table 6. Consequently, carbon dioxide emissions were reduced by 4.8% in 2006 and increased by 10.1% in 2007, since estimates were based on fuel consumption. Methane and nitrous oxide emission were calculated based on mileage in accordance to the GRP, Chapter 7.2 (CCAR, 2008a). Pechan corroborated mileage activity data and methods and agreed with SLVWD emissions estimates. Upon aggregating methane and nitrous oxide with carbon dioxide emissions into single department mobile combustion sources, uncertainty associated with carbon dioxide emissions was reduced. Hence, the overall CO2e estimates by Pechan shown in Tables 4 and 5 are not as large as the 4.8% and 10.1% for carbon dioxide described in Table 6. Final 10 2006-2007 California Climate Action Registry Greenhouse Gas Inventories Verification Report PECHAN December 2008 Table 6. Differences between SLVWD and Pechan Mobile Source Activity Data U155 U311 U339 D650 All 2006 Difference 2.7% -1.1% -0.5% -6.0% -4.8% 2007 Difference 4.7% 1.0% 4.4% 0.0% 10.1% Finally, a few data transfer errors were observed when comparing GASFY and SLVWD emission calculation spreadsheets. Data transfer reporting errors also contributed to the difference in emission estimates between Pechan and SLVWD. Liquid Petroleum Gas (LPG) Combustion The operation of vehicle “740 Toyota forklift” accounted for all mobile combustion resulting from LPG combustion. Pechan found no issues in the selection of methods or results associated with this source. 3.5 Process Direct Emissions Bear Creek Septic System The only process emissions for SLVWD are nitrous oxide emissions associated with the Bear Creek Septic System, which serves about 50 households. This system has a nitrification/denitrification system, and thus would be expected to emit some N2O during removal of nitrates from the wastewater. While methods for estimating N2O from the specific type of system used by SLVWD are not available, the method for centralized wastewater treatment systems with nitrification/denitrification systems was used in order to generate an estimate to gauge the importance of this source. The method (Equation 10.7) comes from the Registry’s Local Government Operations Protocol (Registry, 2008c). Pechan concurs with the use of the Registry’s Local Government Operations (LGO) Protocol (Registry, 2008c) to estimate nitrous oxide emissions. The LGO’s Equation 10.7 best approximates the conditions at SCVWD. The emission factor for Equation 10.7 is 7 grams/person-year. Hence, an annual CO2e estimate, assuming an average of 3 people per household is: 50 HH x 3 people/HH x 7 gN2O/person x 1 t/106 gN2O x 310 (GWP) = 0.33 tCO2e/yr. 3.6 Fugitive Direct Emissions Fugitive Vehicle Refrigerant Emissions The screening method for mobile refrigerant fugitives in the GRP was used to show that HFC emissions are at de minimis levels. This is shown in Tables 4 and 5. In both years, emissions from vehicle refrigerant fugitives are expected to be less than 2% of entity-level emissions. Stationary Refrigeration and Air Conditioning Pechan identified no air conditioning or refrigeration systems that are using HFCs. Fire Suppression Systems As noted under Section 1.1 above, no fire suppression systems were identified that use HFCs or PFCs. Final 2006-2007 California Climate Action Registry 11 Greenhouse Gas Inventories Verification Report PECHAN 3.7 December 2008 De Minimis Sources Pechan’s estimates for de minimis sources agree with SLVWD’s estimates, except for the following: 2006 & 2007 Vehicle fleet ADMIN methane and nitrous oxide emissions differ due to fuel activity issues described in Section 3.4. 2006 Generator-ADMIN as well as 2007 Generator emissions for the administration, operations, and wastewater departments differ due to a difference in approach quantifying LPG usage as described in Section 3.2; and 2007 emissions reported as de minimis for N2O and CH4 (wastewater treatment generators); Pechan identified an error in the spreadsheet calculation which results in emission estimates of less than 0.1 tCO2e. 3.8 Material Misstatements Pechan identified no material misstatements in SLVWD’s CARROT reporting for 2006 or for 2007. 3.9 Immaterial Misstatements Pechan identified the following immaterial misstatements in SLVWD’s CARROT reporting for 2006 and 2007: SLVWD did not include emissions of HFCs from vehicle air conditioners. Pechan’s screening estimates indicate that these would be emitted at levels considered to be de minimis; however, future reporting by SLVWD should include the identification of this source as a de minimis source; Pechan’s direct stationary combustion emissions estimates slightly differ from SLVWD’s estimates due to a difference in approach in the quantification of LPG activity data as described in Section 3.2; and Pechan’s direct mobile combustion estimates differ from SLVWD’s estimates due to discrepancies observed in fuel activity data as described in section 3.3; and Note the issue under Section 3.7 above regarding the wastewater treatment plant generator N2O and CH4 emissions. Once corrected, Pechan suggests that these be reported along with CO2 not as de minimis in the future to avoid confusion by reviewers. 3.10 General Evaluation of Compliance Based on our review of SLVWD’s 2006 and 2007 CARROT reporting, we conclude that it is in compliance with the Registry’s General Reporting Protocol version 3.0. Pechan also has the following additional recommendations to enhance SLVWD’s GHG management program: 1. Pechan recommends that SLVWD develop an Inventory Management Plan that documents the selection of organizational boundaries; identifies emission sources; emission estimation procedures; and data collection and management; Final 12 2006-2007 California Climate Action Registry Greenhouse Gas Inventories Verification Report PECHAN December 2008 2. Pechan recommends the use of direct measurement to estimate diesel consumption in generators; and 3. Pechan recommends maintaining beginning and end of year inventory records in addition to fuel purchases for LPG consumption in generators. 3.11 Verification Conclusion Pechan will verify that SLVWD has had its annual GHG emissions report covering the periods January 1, 2006 to December 31, 2006 and January 1, 2007 to December 31, 2007 verified according to the California Climate Action Registry’s GRP Verification Protocol version 3.0. Pechan identified no material misstatements in SLVWD’s CY2006 and CY2007 GHG reporting to the Registry. Pechan did not identify any other reporting issues that would cause noncompliance with GRP version 3.0. Final 13 2006-2007 California Climate Action Registry Greenhouse Gas Inventories Verification Report PECHAN December 2008 REFERENCES CCAR, 2005. Appendix to the General Reporting Protocol: Power/Utility Reporting Protocol, Reporting Entity-Wide Greenhouse Gas Emissions Produced by Electric Power Generators and Electric Utilities, Version 1.0, April 2005. CCAR, 2008a. General Reporting Protocol, Version 3.0, California Climate Action Registry, April 2008. CCAR, 2008b. General Verification Protocol, Version 3.0, California Climate Action Registry, August 2008. CCAR, 2008c. Local Government Operations Protocol, Version 1.0, California Climate Action Registry, September 2008. Roderos, 2008. Evelyn Roderos, Pacific Gas & Electric, personal communication with H. Lindquist, Pechan, November 2008. Final 14 2006-2007 California Climate Action Registry Greenhouse Gas Inventories Verification Report