Simple Strategies for Managing Missing Emissions Data


Huco Consulting January 11, 2021

What do you do when you find you are missing data for an EI/GHG report that is due around the corner?

This blog reviews this common scenario and how to deal with it. Read about Huco’s best practices for preventing this situation in the first place by implementing streamlined report preparation processes and delegating data collection to operations throughout the year in our November 2020 post.

Are you missing data? 

If you are missing a piece of data for the year, don’t panic. The important thing is to identify these missing data points as soon as possible so you can select the best strategy for managing the situation. 

Assess alternative calculation methods 

First, review the different calculation methodologies for a given source. Required data is calculation-method specific, so if you are missing one piece of information, it is often possible to check an alternate method against the data you have available. For instance, there are 4 methods of calculation for amine units, dependent on the data you collect: 

  • Method 1: CEMS 
  • Method 2: CO2 composition in vent/stack gas 
  • Method 3: CO2 composition in inlet/residue gas and amine throughput volume 
  • Method 4: Simulation software 

If you have sufficient data to complete calculations using another method, try that first.  

Employ missing data procedures 

When the greenhouse gas rules were first released, facilities and suppliers had the option to use the Best Available Monitoring Method (BAMM) to determine emissions from specific sources because it was not always feasible for a facility to acquire, install and operate all of the required monitoring equipment by the required date. 

This changed in 2017, however, and BAMM is no longer an accepted method. Instead, missing data procedures must be utilized for all sources moving forward. This requires you to communicate the following within the Subpart W Spreadsheet: 

  • What piece of data was estimated? 
  • At what frequency is the data usually measured? 
  • How many times were measurements missed? 
  • What procedure was used to estimate the missing data? 

If there is still a lack of data after assessing alternative calculation methods, you will need to employ missing data procedures. These procedures include: 

  1. Standards set by the rule, such as using an emission factor,
  2. The average of other measurements, 
  3. Best engineering estimates, or 
  4. A value that was used in the previous year. 

Verify recordkeeping procedures 

Beyond resolving instances of missing data, it is critical to ensure your data is being properly recorded. 

Operations are required to maintain records on site that document how the data provided in their annual GHG reports were developed. These records include a monitoring plan describing where and when samples were collected, methods used to analyze samples and the procedures used for quality assurance and quality control. 

 Verifying data is collected and maintained as required (for example, records must be kept for at least 3 years following the respective reporting period in a format that is readily available for inspection and review) improves the quality of your reports and will help prevent future data gaps.  

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Are You Ready for Reporting Season?


Huco Consulting Nov. 20, 2020

Best practices and proven processes to streamline reporting

Greenhouse gas (GHG) and state emissions inventory reporting season is a stressful time for many EHS professionals, who often take on most, if not all, of the heavy lifting. The concentration of responsibility on Environmental Managers can lead to time-crunched and frenzied processes – but there’s another way.

In this post, we share best practices for harnessing efficiencies and mobilizing full-team ownership to streamline and simplify seasonal reporting.

Step 1: Start early

While reporting season does not kick off in earnest until January or February, we believe preparation should begin as early as possible. As the following steps demonstrate, looking ahead and managing reporting as an ongoing endeavor distributes the workload across the year and paves the road for an organized, accurate process in the spring.  

Step 2: Check for updates

Checking for regulatory and process updates is the launching point for any reporting plan. These updates fall into 2 categories:

  1. Regulatory changes, which are changes to the rules themselves, and
  2. Report format changes, which are changes that have been made to the excel spreadsheets or xml schema that will be submitted to the agency.

Regulatory changes are usually available at the beginning of the year. Because these may affect how data is collected, the applicability of certain emission sources or how emission calculations are performed, we recommend reviewing these changes as soon as they are available to provide ample time for both configuring necessary changes into the environmental management systems (EMS) and communicating new data needs to operations personnel.

Report format changes can be assessed when the reporting forms are made available, typically in the end of December – though they are occasionally released earlier. Changes to these forms affect how data will be integrated into reports, which, in turn, may require adjustments to your data collection procedures or EMS. Promptly reviewing changes and implementing necessary updates will ensure your processes are calibrated to your requirements, saving you considerable time and potential headaches in March.

After you have reviewed the changes, compare your latest reporting tool (e.g., your eGGRT reporting spreadsheet) to the previous year’s and identify any updates in the formatting or content. You can then compile the changes into a new spreadsheet, compare the new XML reporting schema to the previous year’s, and implement any updates that need to be made.

Step 3: Review changes to your business

Employee turnover, mergers, acquisitions and divestitures are business realities that will impact your reporting requirements to varying degrees each year. Updating asset status changes as soon as they occur, whether this entails updating your entire EMS or simply updating procedures, will streamline your reporting process during the spring time-crunch by clarifying the sources for which you must collect data, as well as from whom you must collect that data.

Step 4: Empower efficient data management

All too often, the bulk of the data collection burden is placed on EHS professionals during reporting season. This not only results in unnecessary process bottlenecks, but in an inefficient allocation of EHS time and expertise as well. We encourage Environmental Managers to break out of this cycle by delegating responsibility to operations personnel, who are advantageously positioned and uniquely qualified to drive efficient data management systems on the ground.

To get the greatest possible value from this full-team approach, data collection should be centralized to allow for the review, analysis and assessment of data from a high level. Centralization optimizes validation processes by enabling EHS managers to reference one source with all the data rather than an array of separate sources. Importantly, centralized systems also reduce instances of data loss, miscommunication and other inefficiencies that are common when coordinating data collection and validation through lengthy email chains or other ad-hoc systems.

There are 3 principal approaches to mobilizing operations for data centralization:

1. Provide operations with a pre-formatted spreadsheet of all the equipment at a given facility and the data that must be collected for that equipment. This approach can be leveraged to increase the consistency of data collection across facilities and to aggregate data from those facilities into a master spreadsheet.

When using spreadsheets to collect data, it may be useful to denote which data will remain the same next year and to pre-populate these fields with default values. Additionally, including data from last year into the spreadsheet may serve as a valuable reference of what the operator filling out the data should expect.

2. Have operations enter data directly into an EMS. EHS personnel can then run reports from the EMS to verify that data is accurate and complete. Note: operators tend to be intimately familiar with the data output. Therefore, the people most familiar with the data are collecting and formatting it, providing initial quality control. In this approach, EHS primarily serves a validation role.

3. Integrate your EMS system with upstream data historians. If the data is already entered in another system or measured directly from electronic instruments, push this data to your reporting system.

Step 5: Validate and submit reports

With more data management responsibility shifted to operations personnel, EHS managers can focus on validating data accuracy. At this point, the centralized data management system helps ensure EHS can include all relevant sites in the validation process, reducing effort and expediting the identification of outliers. An EMS may assist in this process by highlighting missing data or other outliers before submission – similar to how tax software suggests double checking values for accuracy.

Robust report validation is critical before uploading reporting spreadsheets to agency online submission systems. These systems often reject uploads due to invalid picklist options or inaccurate data, using logic and statistical checks against similar facilities as well as algorithm checks – for example, verifying whether quarterly data adds up to the annual total.

Step 6: Jumpstart next year’s process

Reporting is an ongoing endeavor – the job isn’t done when your annual submissions are complete. There are several things you can address now to jumpstart a smooth reporting process next year:

  • Integrate current procedures, roles/responsibilities and work practices into your EHS management system and seize opportunities to streamline your process.
  • If you are still conducting spreadsheet-based reporting, document your procedures and save them to a common location to help share your facility-wide knowledge. This includes identifying which data needs to be gathered and who is responsible for collecting it.
  • Update your data collection procedure or take advantage of any new features to your EMS you may not have been aware of.

By looking ahead, implementing manageable processes, and empowering streamlined systems that leverage your team’s full capacity, you can eliminate bottlenecks and inconsistencies for a smooth and accurate reporting process. Learn more about how Huco can help you tackle reporting season here.


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