CRCF GHG Accounting

This Module is developed for issuing Credits under the EU Carbon Removal and Carbon Farming (CRCF) framework established by EU Regulation 2024/3012.

This Module contains the relevant additional Isometric requirements from our GHG Accounting Module. Any Isometric requirements entirely satisfied by the CRCF Delegated Act Annex methodologies are omitted. Those partially satisfied have been reformulated to build on the framework from the CRCF Delegated Act Annex methodologies.

The following information must be submitted as part of the Re-certification audit of every claimed Removal:

• Supporting information including copies of raw data used. Where data used for emission calculations is not high quality (as defined in Section 3.3), justification for using medium or low-quality data must be provided as part of the Monitoring Report (at the Recertification audit) or the Activity Plan (at Certification).

Operators are responsible for collecting sufficient documentation to support the above information.

In addition to emissions associated with Activity establishment (e.g., capital emissions) and operations (e.g., energy use for capture and storage), Operators must assess and include end-of-life emissions. These are emissions associated with Activities anticipated to occur after the Certification Period but which are directly or indirectly related to it, such as the decommissioning and disposal of the capture and storage facilities.

Leakage is defined as increases in GHG emissions as outside the Activity system boundary that occurs as a result of Activity. This includes, but is not limited to, emissions associated with activity shifting, market leakage, and ecological leakage.

The Operator must identify and quantify all potential sources of Leakage resulting from the Activity. Where an Activity displaces existing activities or services, the associated emissions increase must be accounted for. For example, Bio-CCS Activities must account for any energy leakage associated with reductions in efficiency of wider processes, or reduction in energy outputs as a result of the CDR Activity (See Section 2.1.2.1).

Any secondary reductions in GHG emissions (positive secondary impacts) or secondary sequestration that extend beyond the system boundary are not eligible and must be excluded from the quantification of net CO₂ Removals.

Where an Activity results in foregone energy production, for example if a Bio-CCS Activity decreases the amount of energy being exported to the grid due to the energy requirements of the capture facility, the following must be considered.

Energy leakage is a subset of Leakage identified in Section 2.1.2 and must be considered as part of the $CO_2e_{MarketLeakage}$ term. This represents the indirect greenhouse gas emissions arising when an Activity creates a parasitic load that reduces the net energy export from the facility. The CRCF term $GHG_{bio}$ must always be calculated and accounted for under the relevant Protocol. This must be subtracted from $CO_2e_{EnergyLeakage}$ according to Equation 1 to ensure the Activity is not double-penalised for emissions associated with parasitic load. In some cases, where an electricity emission factor is low or heat substitution is high, this may result in value that is immaterial to the Activity accounting.

$$CO_2e_{EnergyLeakage} = \max\!\Big(\boldsymbol[ \max(Q_{elec}, 0) \cdot EF_{elec} + \max(Q_{heat}, 0) \cdot EF_{heat,displaced} - GHG_{bio} - CO_2e_{HeatSubstitution}\boldsymbol], \boldsymbol[0\boldsymbol]\Big)$$

Equation 1

Where:

• $Q_{elec}$ is the net consumption of facility electricity consumed by the capture facility specifically, as defined in the Protocol;

• $EF_{elec}$ is the emission factor for the derated electricity, expressed in tCO₂e/unit, selected in accordance with CRCF requirements for grid electricity;

• $Q_{heat}$ is the net consumption of the facility heat consumed by the capture facility, as defined in the Protocol;

• $EF_{heat,displaced}$ is the average emission factor for district heating for the region, expressed in tCO₂e/unit;

• $GHG_{bio}$ is the emissions due to the supply of biomass that is used to generate energy consumed by the capture process, equivalent to the CRCF term $GHG_{bio}$ and calculated in accordance with equation [19] in the Protocol; and

• $CO_2e_{HeatSubstitution}$ is the emissions avoided through the export of useful heat that is produced as a new co-product of the capture process, calculated in accordance with Equation 2 below.

$CO_2e_{HeatSubstitution}$ is quantified as per Equation 2 below.

$$CO_2e_{HeatSubstitution} = Q_{heat,CCS} \cdot EF_{heat,displaced} \cdot CF$$

Equation 2

Where:

• $Q_{heat,CCS}$ is the quantity of useful heat that is exported from the facility as a new co-product that is directly attributable to the operation of the capture process, expressed in appropriate units. This shall include only heat that would not have been exported in the absence of the capture process (e.g., waste heat recovered from solvent regeneration, CO₂ compression, or CO₂ conditioning);

• $EF_{heat,displaced}$ is the emission factor of district heating in the region, selected in accordance with the relevant Protocol, expressed in tCO₂e/unit. The same value shall be used as in Equation 1; and

• $CF$ is the conservatism factor, which defaults to 0.5. Activities may propose a lower discount, which must be justified with supporting evidence, such as verified product displacement data or binding statements from co-product buyers. For heat substitution a direct line is required to justify a lower discount.

This section sets out the data quality hierarchy and the data quality principles that must be considered for every input parameter.

Operators must use data that best represents the activity included in the Monitoring Report and is aligned to data quality hierarchy and principles as outlined in Section 3.3.

The quality of data used in GHG accounting underpins the accuracy of results. GHG accounting as a practice is inherently uncertain as it is based on estimated data, unless emissions are measured directly (such as in flue gas measurements).

This Module defines three types of data:

• Direct CO₂e measurements: Direct measurement of CO₂ removals or GHG emissions via apparatus that detects concentration of C, CO₂, or other GHGs within a sample, or output flow. This type of data is provided by the Operator, or supply chain members. Removals or emissions are determined from direct measurements, for example direct measurement of C content of biomass, or direct measurement of GHGs in flue gas.
• Primary data: Activity data that is specific to Operator activities and it is directly measured, but is not a direct measurement of CO₂e. Examples are electricity and natural gas data from automatic meter readings; fuel quantity data from invoices; number of units or quantity in tonnes of materials and resources from a bill of quantity (BoQ). This type of data is provided by the Operators or supply chain members.
• Secondary data: Data that is not specific to Operator activities. This type of data is publicly available, for example from a database or publication. This type of data may be specific to a similar activity to that is being quantified, or it may be an average, for example a regional, sectoral or global average. Examples include benchmarks related to the energy consumption of specific assets, such as the average kWh/sqm for offices, or estimating fuel quantities from expenditure data, e.g., using the average price per litre of diesel within a specific geography. Emission factors and proxies for activity data are examples of secondary data. Expenditure data is also considered a type of secondary data.

Requirements for direct CO₂e measurements are set out in Protocols. For all other data points, primary data must always be used over secondary data when collecting activity data, as secondary data carries more uncertainty than primary data. This is especially important for emission sources which are likely to be material for the Monitoring Report

Section 3.3 provides guidance on the data quality hierarchy to be followed for both activity data and emission factors.

Data must follow the requirements set out in the relevant Protocols and Modules. Whenever specific data quality requirements are included in a Protocol or relevant Module(s), for example storage Modules or emissions accounting Modules, they must be followed.

Where direct measurements are not available for the SSRs relevant to the system boundary, the Operator must gather the highest quality data available to estimate emissions, following the principles and quality hierarchies outlined in this section.

Each data should be selected considering the following data quality criteria: Reliability, Completeness, Age, Geography, and Technology. A brief description of these criteria is provided in Table 1, while Table 2 and Table 3 provide high level descriptions of what constitutes high, medium, and low quality for each criteria for both activity data and emission factors, respectively. Detailed descriptions of these criteria are provided in Appendix A.

The data quality hierarchy serves as a guide for Operators to distinguish between high and low-quality data, enhance the transparency of the Monitoring Report, and encourage the continuous pursuit of the best available data. Operators who must use data that is not ideal (e.g., global instead of geography-specific, or older than eight years) will not be penalised if no better alternatives are available.

Where high quality data is not available to an Operator, justification for using medium or low quality data for the relevant SSR must be provided either within the Monitoring Report (at the Re-certification audit stage) or the Activity Plan (at the Certification audit stage).

Justification must include:

• A statement that higher quality data was not available at the time of the assessment

Justification may also include:

• Evidence that an attempt was made to gather higher quality data
• Commitments to continually improve data quality for subsequent Certification Period

Justification must be assessed during every re-certification audit, though it may remain unchanged if circumstances have not evolved. The ongoing acceptance of medium or low-quality data will be determined by the Certification Body, based on conservatism, scope, materiality, and Activity-specific factors. For one-time emissions, typically related to Activity establishment and end-of-life emissions, which can be amortised over multiple Certification Periods, justifications provided and deemed acceptable at the first Re-certification Audit event do not require any further action.

Materiality may be used as a justification for applying lower-quality data when an emission source accounts < 1% of net removals. Emission sources using this justification must collectively represent < 1% of net removals. If the cumulative total of these SSRs exceeds 1%, Operators should seek higher-quality data, starting with the SSRs that have the highest contribution.

Table 1. Data quality criteria descriptions¹. Refer to Appendix A for further detail.

Table 2. Data quality hierarchy for activity data¹ . Refer to Appendix A for further detail.

Table 3. Data quality hierarchy for emission factors. Refer to Appendix A for further detail

Once the highest quality data have been identified based on the above criteria, the Operator must also consider Scope and Conservativeness (Table 4). Scope refers to the degree to which the data is representative of the relevant activity. Conservativeness refers to the degree to which the data is conservative.

Table 4. Scope and conservativeness

Conservative values and assumptions are those that are more likely to underestimate than overestimate net CO₂e removals.

Conservative input parameters must be selected when determining which data to use. For example, there may be instances where there are multiple emission factors for an activity type and no indication from activity data on which might be the most appropriate to select. In this instance the highest, and therefore most conservative, emission factor should be selected. Or, if there is a gap in natural gas consumption data and different values are available from previous years for a similar period, the more conservative value should be used to fill the gap.

Conservative estimates of input parameters must be made in any cases where there is more than one possible input parameter to select from, and all options are equal in all other aspects of data quality. However, if a less conservative input parameter is more representative, it should be selected. This applies to all data types.

For each input parameter, including emission factors selected or assumptions made on activity data, justification for how the input parameter is conservative must be included in the Activity plan.

Improving the quality of activity data used by moving up the activity data quality hierarchy typically will reduce the number of conservative assumptions required in GHG accounting, therefore likely leading to an increase in net CO₂e removals.

The following sections outline GHG accounting considerations for specific categories of emission sources that commonly occur in relation to Activities. These categories of emission sources are not mutually exclusive to Activity phases.

Where available, capital emissions calculations must include the following life cycle stages of the product, consumable, building or infrastructure asset, as defined by ISO 21930 and EN15804 and as referenced in the GHG Protocol supplement ², including:

• A1-A3 - Product Stage: includes raw material sourcing, transport to manufacturing facility and manufacturing;
• A4 - Transport to activity site
• A5 - Construction Stage: includes fuel and energy use, as well as waste generated during installation at site
• C1-C4 - End of Life Stage: includes demolition, transport, waste processing and final disposal

When reporting emissions of materials and products procured, for example, concrete and steel used in construction, Operators must report at a minimum emissions related to modules A1-A3. A4, A5 and C1-C4 may be captured separately by Operators where primary activity data flows for these stages are captured separately.

B1-B5 & B7 - Use Stage emissions (includes use, maintenance, repair, replacement, refurbishment and water consumption) are not included in the above list, as these are monitored and reported each certification period as they occur.

In addition to GHG emissions from the direct combustion of fuels in vehicles, as well as the upstream emissions associated with the production and distribution of the fuel and/or electricity, a full cradle-to-grave GHG assessment is required for vehicles and infrastructure produced, constructed, and utilised for the Activity, in line with Section 4.1.

Further to the approaches identified in the main CRCF protocol, i.e., the Fuel-Based Method (also referred to as Energy Usage Method) and the Distance-Based Method, transportation can also be calculated by using the following approach:

• Mass-Distance-Based Method: uses the distance travelled, transport mode, and load weight with associated emissions factors.

Emissions are calculated as follows:

$${CO}_{2}^{}e_{Transportation,\ j}^{}\  = \ D_{j}^{}\  \times \ W_{j}^{}\  \times \ {EF}_{Transportation,\ j}^{}$$

Equation 3

Where:

• $D_{j}^{}$ is the distance travelled for the transportation journey, $j$, from one location to another, in appropriate units e.g. km;
• $W_{j}^{}$ is the mass of material transported as part of the transportation journey, $j$, from one location to another, in appropriate units e.g. tonnes; and
• ${EF}_{Transportation,\ j}^{}$ is the weight- and distance-based emission factor for transportation for a specific vehicle type, or infrastructure asset where available, provided in appropriate units e.g. kg CO₂e/tonne-km.

The Energy Usage Method must always be prioritised. Where it is not possible to use the Energy Usage Method due to lack of data and this is appropriately evidenced, the Mass-Distance-Based Method may be used. The distance-based method should be used for non-freight related transport, such as passenger transport. Other approaches may be allowable on a case-by-case basis in agreement with Isometric.

Consumed electricity is attributed an emission factor of zero only where it qualifies as "fully renewable". CRCF imports this qualification via paragraph 5 of Part A of the Annex to Commission Delegated Regulation (EU) 2023/1185, which defers to Article 27(3) of Directive (EU) 2018/2001. The operational criteria for "fully renewable" status are set in Commission Delegated Regulation (EU) 2023/1184, Article 4 of which establishes four mutually-alternative pathways.

Under this Module, only the pathway in Article 4(4) of 2023/1184 is admissible. Pathways 1, 2, and 3 attribute renewable status to consumed electricity on the basis of grid-level proxies (bidding-zone renewables share, low-carbon intensity, or curtailment-absorption hours) rather than activity-specific procurement of additional renewable generation. For carbon removal, where each credited tonne must reflect a real net atmospheric outcome, only the activity-level additionality test in Article 4(4)'s pathway gives the assurance that the Activity's consumption is supplied by renewable generation that would not otherwise have existed. Article 11 of 2023/1184, which deactivates the additionality requirement of Article 5 until 1 January 2038 for installations operating before 1 January 2028, is also not permitted under this Module.

The emission factor applied for emission calculations associated with electricity procured from the grid must:

• Be technology-specific to the mix of electricity generation methods in the connected electric grid;
• Be reported on a residual-mix basis, meaning that any generators within a grid region which are subject to contract purchase (e.g. through Guarantees of Origins) are excluded from the average emissions calculation. Operators must declare whether such data is available in the region of operation, and utilise such data wherever possible. Where residual mix factors are not available, national grid average factors are considered acceptable;
• Be reported on a consumption basis, meaning that all net physical energy imports/exports across the grid boundary should be reflected;
• Account for the full life cycle emissions associated with electricity generation, including direct emissions from power generation, transmission and distribution losses, and upstream life cycle emissions associated with extraction, refining and transportation of primary fuels (i.e., from cradle-to-gate);
• Be for the most recent published year. Wherever possible, the utilised emissions factors must correspond to those most recently published by the relevant authority in the region of Activity operations.

The emission factor applied for emission calculations associated with procured renewable energy must:

• Be technology-specific to the method of electricity generation;
• Account for all capital emissions associated with the establishment of procured generators by amortising on a per unit electricity generation basis. If capital emissions are not included within the used emissions factor, then they must be calculated separately and allocated to the Activity on a proportional basis relative to the usage of the generating asset over its anticipated lifetime and generation capacity;
• Account for the full life cycle emissions associated with electricity generation and include direct emissions from power generation (i.e., fuel combustion), upstream emissions associated with fuel production, equipment manufacture, and equipment decommissioning and disposal at a minimum;
• Account for any necessary derating factors associated with energy loss during transmission between the generating facility and the Activity. Where derating factors are not applied in the utilised emissions factors, the Operator must additionally account for these. For example, derating factors for transmission losses may be estimated using the approach of Sadovskaia et al. (2019)⁴, or any other suitably justified method.

Capital emissions associated with system inputs considered to be waste products can be excluded from the accounting of the system boundary provided the appropriate criteria are met. A waste product is defined as an output of a process that has no intended value to the producer.

For waste heat, the criteria described in Table 5 must be met for the waste heat to be eligible for discounting against Activity heat usage.
Any activities specifically developed inside the Activity gate to handle and utilise waste heat must be accounted for in the life cycle analysis. These potentially include, but are not limited to:

• Waste heat distribution systems, including pumps, piping, or other equipment;
• Waste heat upgrading processes, such as heat pumps, booster pumps, other other equipment; and
• Waste heat conversion processes, such as heat-to-power technologies (e.g., organic Rankine cycle generators).

Waste heat must meet all of the criteria in Table 5 to be considered exempt from GHG emissions accounting:

Table 5: Eligibility criteria for waste heat inputs

For all other waste products used as inputs, with the exception of biomass, the following criteria must be considered.

If EC3 or both EC4 and EC5 are satisfied, then capital and leakage emissions associated with the waste input may be excluded from the system boundary. This is further detailed below.

If EC3 in Table 6 is satisfied, capital emissions associated with the waste product used as input can be excluded from the system boundary. Market leakage emissions associated with waste inputs may also be excluded from the system boundary, as compliance with EC3 would result in no change to the waste producer behavior (i.e., no market leakage) and indicates there are no alternative users of the waste product (i.e. no replacement emissions).

Table 6. Waste input emissions exclusion criteria, EC3

If EC4 and EC5 in Table 7 are both satisfied, capital emissions associated with the waste product input can be excluded from the system boundary. Market leakage emissions associated with waste inputs may also be excluded from the system boundary, as compliance with EC4 and EC5 would result in no significant change to the waste producer behavior (i.e. no market leakage) and there are no alternative use cases for the waste product (i.e. no replacement emissions).

Table 7. Waste input emissions exclusion criteria, EC4 and EC5

Activities utilising waste inputs must validate and demonstrate compliance with eligibility requirements according to the following rules.

For waste inputs that are used once within the scope of a Activity (for example, construction materials), Certification Audit and compliance with eligibility requirements demonstrated at the time of initial use is sufficient. The Operator must document and retain evidence demonstrating that the waste input met eligibility requirements at the time of its use.

For waste inputs that are used on an ongoing basis throughout the Activity:

• Waste input compliance must be re-certified whenever a material change occurs, and
• At a minimum, re-certification must occur at least once every ten years.

Material changes that trigger re-certification include, but are not limited to:

• A change in the waste provider.
• A change in the price paid for the waste material.
• Amendments to the contract between the Operator and the waste provider.
• Significant changes to the upstream production or handling of the waste input (e.g., if the waste provider no longer produces the waste internally and instead procures it from third-parties).

Operators should consider re-certifying waste input eligibility at their discretion in response to broader market developments that could affect the characterisation of the input as waste (e.g., increased media scrutiny, emerging regulatory changes, or shifts in market dynamics).

Inputs to a CDR process, such as feedstocks, may be by-products or co-products under a separate system. Where a life cycle analysis specific to the sub-process is not available, Operators may seek to undergo emissions allocation to determine an appropriate emissions factor for the input material, following a stepwise process. Allocation refers to the partitioning of the inputs or outputs of a process or product system between the product system under study and one or more other product systems.

Operators must follow best practice guidance to undertake allocation of other product systems, such as:

• ISO 14044: 2006
• GHG Protocol Product Life Cycle Accounting and Reporting Standard
• Product Category Rules
• Government Standards

Where it is possible to undertake more than one emission allocation approach, the results of all approaches must be documented. Evidence must be provided to determine why the selected approach is acceptable and how it is conservative in line with Isometric uncertainty requirements.

Operators that amortise emissions as outlined in the relevant Protocol must report the residual emission debt at every re-certification audit. Activities that initially amortise emissions may later elect to deduct the remaining unamortised emissions in full from a subsequent removal verification, thereby transitioning to a one-time deduction approach. This provides flexibility for Activities that wish to simplify reporting or consolidate emissions accounting at a later stage.

Tables A1 (Activity data) and Table A2 (Emission factors) provide examples for what constitutes high, medium, and low quality data under each criteria. The data and assumptions used in the GHG Statement will ultimately be dependent on the Activity, and the tables below are meant to serve as guidance only.

Table A1: Detailed data quality hierarchy for activity data

Table A2: Detailed data quality hierarchy for emission factors

Capital emissions should be calculated based on quantities of materials, equipment or products and representative capital emission factors for the specific components.

Examples of high quality activity data are:

• An Activity inventory that details the number/ weight of products, materials or equipment used for the Activity, such as a cost plan or bill of quantities.
• Purchase records with product quantities and manufacturer specifications which have a corresponding EPD.

Examples of high quality emission factors are:

• Independently verified life cycle analysis for the material or product completed in accordance with ISO 14040 or similar guidelines.
• An environmental product declaration (EPD) for a material or product completed and independently verified in accordance with ISO 14025, ISO 2193 0, EN 15804 or equivalent standards.

The calculations should utilise approaches outlined in the Sector Supplement for Measuring and Accounting for Embodied Emissions in the Built Environment: A Guide for measuring and reporting embodied emissions using the Greenhouse Gas Protocol version 1.1 - November 2021, specifically:

• Chapter 7: Identifying Products within system boundary in determining the list and inventory of equipment, products, and materials used in the manufacturing, construction, and installation of the Activity facility and equipment; and
• Chapter 8: Identifying Data Sources and Collecting Data for selecting and utilising appropriate emission factors for such products and equipment. In line with Chapter 8, when gathering emission factors for capital emissions, the following should be extracted and transparently reported:
  • Data source
  • Specific emission factor used
  • EPD product name which matches the product inventory
  • EPD Expiration Date
  • Verification record of LCA or EPD (external third party or other)
  • Functional Unit
  • Global Warming Potential (GWP) Annex I following GWP100 from Delegated Regulation (EU) 2020/1044
  • LCA Modules included

For the Energy Usage Method, emission factors must:

• Be for the specific type of fuel utilised in the vehicle (e.g. on-road diesel, biodiesel, gasoline, E-85, electricity)
• Include all emissions associated with the fuel-cycle, such as direct combustion of fuel as well as indirect upstream emissions, including production and distribution of fuel or electricity

For the Distance-Based Method, emissions factors must:

• Be selected for the specific vehicle type and age being utilised (e.g., Class 8 heavy-duty long-haul truck, Class 6 medium-duty truck, etc.)
• Account for vehicle loading/capacity utilisation (e.g., 50% capacity)
• Include all emissions associated with the fuel-cycle such as direct combustion of fuel as well as indirect upstream emissions, including production and distribution of fuel or electricity

GHG emissions from transportation sources must be evaluated for all transportation completed between facilities, from the gate of one facility to the gate of the next facility, including return journeys. Primary measurements considered in calculation of emissions are:

• $F_{j}^{}$ (fuel/ electricity consumed)
• $D_{j}^{}$ (distance travelled)
• $W_{j}^{}$ (weight of vehicle load)

The fuel consumed, $F_{j}^{}$ , can be determined by one of the following methods:

• Fuel/ electricity metering for vehicles, including data from calibrated on-board flow meters
• Fuel/ electricity receipts
• Fuel/ electricity metering for pipeline transport
• Fuel/ electricity usage data from fleet monitoring systems or software
• Fuel/ electricity usage values provided by outputs of on-board vehicle diagnostic systems (OBD)
• Fuel/ electricity efficiency (e.g. miles/gallon) data for transport vehicles used and distance travelled, to estimate fuel/ electricity use

The distance travelled, $D_{j}^{}$, can be determined by one of the following methods:

• Recording of vehicle odometer reading before and after completion of trip
• Recording of travel distance by vehicle fleet management system
• Online mapping of route travelled using common mapping platforms (e.g., Google Maps) and exact start and end trip locations
• Other justifiable methods that account for actual route travelled for each shipment

Distance travelled and fuel usage must consider:

• Full round trip distance of vehicle travelled when vehicle returns to origination site unloaded, or if next destination is unknown; or
• Full distance of one-way trip plus distance of trip to the next destination

Evidence must be provided showing the distance of every trip to the next destination if the second option is used. When no onwards journey information is available, the full round trip must be assumed in calculations.

Calculations shall be completed separately for each leg of the trip associated with a removal, with total emissions calculated by the sum of emissions from each leg.

Weight of the material being shipped, $W_{j}^{}$, should be determined as loaded gross vehicle weight measured at facility gate of departure minus vehicle gross weight upon facility entry, as determined by calibrated a weigh scale.

Required records for each transportation leg calculated using the Energy Usage Method include:

• Documentation of fuel consumed
• Citation and description of emission factors used

Required records for each transportation leg calculated using the Distance-Based Method include:

• Weigh scale tickets or similar documentation at each location to document load weight transported
• Weigh scale calibration record
• Bill of lading or similar transportation documentation indicating load type/contents, quantity, and pickup and delivery location
• Documentation of vehicle destination after drop off, to account for determination of inclusion of return trip
• Documentation of vehicle type and class used, including, whenever possible, vehicle (i.e., truck) class and model year

Any use of book and claim mechanisms to reduce reported transportation emissions should be transparently disclosed, in line with the Energy Use Accounting Module v1.3⁵. Any meters used must be calibrated for the fuel being used both initially and at regular intervals in accordance with manufacturer specifications.

Recommendations for additional considerations for four common modes of transportation (road, rail, ship, and pipeline) are included below.

Road:

• Resolution: The payload of the truck should be considered. Different emissions factors take payload into consideration differently. In general, higher payload utilisations translate to lower emissions on a per-metric-tonne-kilometer basis despite the increased fuel burn from transporting more mass.
• Timing: Due to relatively rapid changes in road transportation emissions regulation and technologies, utilised emissions factors should not be more than three years old. The most recent emissions factors available must be used.

Rail:

• Resolution: An emissions factor considering the source of the fuel should be used, with minimum resolution covering the use of diesel or electricity.
• Timing: Due to slower innovation in the locomotive space, utilised emissions factors should not be more than seven years old.

Ship:

• Resolution: Emissions factors matching the general type of ship (bulk carrier, tanker, barge, and cargo/container ship) and the general type of fuel (HFO, MDO, MGO, LNG, biodiesel, ammonia, hydrogen, or methanol) should be used.
• Timing: Utilised emissions factors should not be more than five years old.

Pipeline:

• Resolution: Most pipeline emissions factors are for natural gas and petroleum products and should be assigned accordingly. For transport of other products, direct energy needs for pipeline transportation should be calculated and multiplied by corresponding fuel-cycle emissions factors to estimate transportation impacts. If this is not possible, a petroleum product pipeline transportation emissions factor should be used. The natural gas factor is inflated due to consideration of methane leakage, which would not apply to most other products.
• Timing: Due to slower innovation in the pipeline space, utilised emissions factors should not be more than seven years old.

Aircraft:

• Resolution: Emissions factors for transportation via aviation should consider non-CO₂ impacts generated during combustion. Such impacts can arise from more than solely non-CO₂ GHGs due to the complex dynamics occurring during high-altitude combustion. The full impact can be determined using an appropriate radiative forcing multiplier. The UK Department for Energy Security and Net Zero recommends a multiplier of 1.7.⁶
• Timing: Utilised emissions factors should not be more than five years old.

1. Adapted from https://ghgprotocol.org/sites/default/files/standards/Product-Life-Cycle-Accounting-Reporting-Standard_041613.pdf ↩ ↩²

2. Referenced in the Sector Supplement for Measuring and Accounting for Embodied Emissions in the Built Environment A Guide for measuring and reporting embodied emissions using the Greenhouse Gas Protocol version 1.1 - November 2021. ↩

3. A tipping fee refers to an amount paid by the Operator to the producer of the waste to collect the waste. A tipping fee should only cover transportation and collection costs. ↩

4. The 5% threshold is drawn from the SEC Staff Accounting Bulletin No. 99, an investor-focused standard for significance. This is a widely recognised benchmark for assessing materiality in financial reporting and provides a basis for determining when payments are immaterial. https://www.sec.gov/interps/account/sab99.htm ↩

5. The Energy Use Accounting Module is pending a v1.3 update. For the purposes of the GHG Accounting Module v1.0, the Energy Use Accounting Module v1.3 update will cover the inclusion of Book-and-Claim unit requirements, which will be transferred from the Transportation Emissions Accounting Module v1.1. The Transportation Emissions Accounting Module and the Embodied Emissions Accounting Module are no longer maintained for updates, because the relevant content is transferred to the GHG Accounting Module v1.0 and the Energy Use Accounting Module v1.3. ↩

6. https://www.gov.uk/government/publications/greenhouse-gas-reporting-conversion-factors-2025 ↩