MA Emissions Reporting Starts Jan 1 - Are You Ready?
The next chapter of Massachusetts Climate Change regulation kicks on January 1st with emissions and storage reporting requirements for the DEP due throughout 2025 ahead of the full enactment of the Clean Heat Standard kicking on in January 2026.
Wait, what reporting? All suppliers of heating oil, diesel, propane, and natural gas need to register with the DEP by January 31 and will be required to submit reporting quarterly detailing supply and emissions information. Storage facilities for energy products are subject to similar reporting, but on a month-to-month basis. Both categories are required to report on fuel supply or shipments into the State of Mass starting January 1, 2025.
What’s this reporting for? The reporting will inform the DEP on the gallons of fuel used for heat and energy in the State (sold by retailers, or imported in by suppliers). This will effectively function as a source list for where emissions can be traced to, and what their volumes ought to look like over time, so the DEP can use this information to better understand the landscape and what adjustments need to be made for the State to continue progress toward its established Climate goals via the Clean Heat Standard that takes effect in 2026.
But what is the Clean Heat Standard anyway?
Clean Heat Standards seek to lower emissions through setting continually declining maximum emissions for obligated parties. Conceptually, it works much like the rolling emissions limits on passenger vehicles have worked – limits drop by year and producers are subject to the new limits as they are established. The Clean Heat Standard not only pushes movement toward clean measures but establishes a credit system to track compliance. Companies would receive credit, for example, for moving a customer to heat pumps, or using biofuel blends. To hit required credits and be in compliance, suppliers would either need to be aggressively using renewables or moving customers to more renewable setups like heat pumps, split credit with other types of suppliers like heat pump installers, or purchase Alternative Compliance Credits.
Because of the authority laid out in prior MA Climate laws and their having been upheld by the State Supreme Court, the DEP has the authority to develop a Clean Heat Standard for the State without requiring legislation to be enacted.
The tentative framework for the CHS in Massachusetts was laid out in 2023, but final draft regulation is expected to drop by the end of 2024 – if you are keeping score at home, that means in the next 2 weeks. The program will take full effect in 2026, BUT starting January 2025, the reporting requirement for suppliers to the DEP mentioned above takes effect.
So what do you need to do?
If you want to find out if your company is subject to the reporting requirements, or just want info on the legal basis and the outlined goals of the reporting requirements, the State of MA has a lot of good information outlined here: MassDEP Greenhouse Gas Emissions Reporting Program | Mass.gov . Most importantly - if your company is subject to the reporting requirements for 2025, don’t forget to register by January 31 here: chets.apx.com
