What Falls Short With Emissions Factors

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What Falls Short With Emissions Factors

Emissions factors are a popular way to capture data about greenhouse gas. They show emissions related data for everything from refrigeration to electricity generation. They also help with showing emissions reported through representative value for content such as ESG reports.

New emissions factors are often popping up from sources such as IPCC guidelines and authorities including the Environmental Protection Agency. Businesses often flock to them to them, thinking they are a great new way to show pollutant released from GHG emissions. Especially with entities such as the SEC and state governments requiring information on emission sources, an emissions factor can seem like an easy way to provide needed data.

While they are popular, though, emission factors are not always accurate in the GHG emission and energy consumption data they provide. Information about greenhouse gases can be off, and the way that an emission factor calculates emissions may not take into account everything that it should, including everything from HFCs to nitrogen oxides.

We decided to dive into some popular emissions factors and show how the specific data sets don’t exactly stack up. Our analysis will show why users of them should be wary. We’ll also delve into why you should be using technology, tools, and resources to track information for yourself and your industry rather than relying on factors to show how you are impacting the atmosphere.

What is an emissions factor?

But first of all – what is an emissions factor?

According to the EPA, an emissions factor is a representative value that attempts to relate the quantity of a pollutant released to the atmosphere with an activity associated with the release of that pollutant. These factors are usually expressed as the weight of pollutant divided by a unit weight, volume, distance, or duration of the activity emitting the pollutant (e.g., kilograms of particulate emitted per megagram of coal burned).

The general equation for emissions estimation is:

E = A x EF x (1-ER/100)


  • E = emissions;
  • A = activity rate;
  • EF = emission factor, and
  • ER =overall emission reduction efficiency, %


Environmental Protection Agency Acknowledges Uncertainties in Emissions Factors

The Environmental Protection Agency acknowledges that there is uncertainty in emissions factors. After all, they are not providing auditable data. They are providing something better than an estimate, but the information is still coming from a formula rather than tracked data.

The Environmental Protection Agency states that uncertainty is dependent on the kind of emissions released, the number of tests used to determine the emissions factor, the appropriate decision level (or percentile) within the distribution range, and the number of similar emissions units within a specific area.

We believe there are even more uncertainties and dilemmas to delve into when it comes to emissions factors, ranging from focusing on the wrong types of GHG emission to more specific parts of the formulas in play.


Greenhouse Gas Protocol Logo


Greenhouse Gas Protocol Emissions Factor

The Greenhouse Gas Protocol Emissions Factor is one of many conversion factors available on the web. This emissions factor can be found here.

Background on the Emissions Factor

The emissions factor notes that leaks in your company’s HVAC system, chillers, and refrigerators are all part of the equation that they are using since these emissions all lead to climate change. It also acknowledges that refrigeration and air conditioning are comprised of many end-uses that have traditionally led to the production and emission of ozone-depleting substances. These gases have 100-year global warming potentials (GWP) 140 to 11,700 times that of carbon dioxide, so their impact on climate change is significant, and curbing these emissions is crucial for air quality.

This factor notes that HFC and PFC emissions can be calculated based on information readily available to companies. The methodology splits into three approaches from here. Approach 1 and 2, the Sales-Based Approach, is lauded as the most accurate and easy-to-use. This approach estimates HFC and PFC emissions based on the amount of refrigerant purchased and used by the equipment manufacturer or user. This means that data must be available from entity purchases and service records. Approach 1 is for equipment manufacturers, and Approach 2 is for equipment users.

Approach 3 is the Life-Cycle Stage Approach. This requires compiling information from contractors working with refrigeration to evaluate emissions. It provides a reasonable estimate of emissions from equipment, and tracks emissions from installation, servicing, and disposal.

Using The Factor

When using this emissions factor, the user decides which approach they want to use based on identified inventory and their relationship to refrigeration. From there, the user enters information by facility and year. This information includes:

  • Type of air conditioning and refrigeration equipment
  • Refrigerant used
  • Refrigerant inventory at the beginning of the year
  • Refrigerant inventory at the end of the year
  • Refrigerant purchased from producers and distributors
  • Refrigerant returned by equipment users
  • Refrigerant returned after off-site recycling or reclamation
  • Refrigerant charged into equipment
  • Refrigerant delivered to equipment users in containers
  • Refrigerant returned to refrigerant producers
  • Refrigerant sent off-site for recycling or reclamation
  • Refrigerant sent off-site for destruction

With all this information, the emission factor calculates CO2 equivalent emissions in tons.

To calculate refrigerant charged into equipment, the emissions factor has a separate section. In this section, the user inputs:

  • Nameplate capacity of partially charged equipment
  • Density or pressure of partially charged equipment
  • Density or pressure of full charge

With this information, the emissions factor determines refrigerant charged into the equipment.

The problem with this emissions factor

We have one main problem with this emissions factor: it suggests that you should not report on or include HCFC refrigerants, since they are on phase-out lists anyway.

Our main piece of feedback is that this is misguided. These gases make up 50% of the refrigeration market. If we want a tool to accurately access information on emissions, HCFCs must be part of them. Just because they are being phased out does not mean that they are obsolete yet.

This emissions factor also focuses on macro data. The data is not focusing on specifics like location and assets – it’s looking at emissions more broadly, creating estimates rather than accurate, auditable data. This means a company using this emissions factor won’t be able to drill down and find issues with specific outliers to improve.

The GHG factor ignores the idea that materials can actually be tracked and changes can be made to improve. It allows companies to feel comfortable in using estimates, rather than moving them forward into tracking best practices. Accurate tracking is where the future of emissions reporting is, and this factor allows companies to stay in the past.


The Climate Registry Logo



The Climate Registry Emissions Factor

The Climate Registry also has its own emissions factor, CRIS. You can access it here.

This emissions factor uses methodology from two methods of estimating HCFCs and PFCs: the simplified mass balance approach and the screening method.

Simplified Mass Balance Method

This method is often used by entities that do not maintain and track stock of refrigerants, and that have not retrofitted equipment to use a different refrigerant during the reporting period. This method tracks emissions from equipment installation, operation, and disposal.

The method requires data on the quantity of refrigerant: (a) used to fill new equipment during installation, (b) used to service equipment, and (c) recovered from retiring equipment, as well as the total refrigerant capacities of new and retiring equipment.

Screening Method

The Screening Method requires organizations to determine the following information:

  •  Type of equipment
  • Number of units
  • Refrigerant or fire suppressant materials used
  • Total refrigerant or fire suppressant charge for the equipment (lb.)

For refrigeration, process cooling, and air conditioning equipment, the additional information is required:

  • Assembly emission factor (%)
  • Annual leakage rate (%)
  • Percent of capacity remaining at disposal (%)
  • Recovery efficiency (%)

The Screening Method is based on the Tier 2 approach from the 2006 Intergovernmental Panel on Climate Change (IPCC) Guidelines for National Greenhouse Gas Inventories. The IPCC guidelines also include a table of emission factors for the different phases of the equipment’s life by equipment type. The IPCC table provides a range of values for the different emission factors, the percent remaining at disposal, and the recovery efficiency. However, since this method is intended as a screening approach, it is recommended that the upper end of the ranges be used.

The problem with this emissions factor

This emission factor may seem like a great way to access GHG emissions on the surface. After all, it is using two standard calculation approaches.

However, we see a major problem with it. This emission factor is based on market generalizations.

It may seem obvious that what applies to a grocery store wouldn’t apply to a retail store, and what applies to both of those wouldn’t apply to a QSR. However, emissions factors like this assume that, even though it’s a problematic approach.

A better factor should be able to provide discreet data by sector. If you’re in a retail store, data should be available specifically for that. If you’re in grocery, discreet data should be available for your sector as well. Other sectors will also need unique ways of calculating data that make sense for their industry.

Using the Mass Balance Approach also leads to what we call “phantom emissions.” These emissions are emissions that didn’t happen – you’re only counting what is going in and going out of your systems, instead of accounting for other sources such as stored refrigerants. This will lead to reporting on events that haven’t really happened, undermining accountability.

Like the GHG Protocol, this emissions factor also only provides estimates. It does not produce auditable data, and misses entire groups of refrigerants. This once again allows companies to feel comfortable with faulty data for reporting rather than pushing forward into better tracking.


EPA logo


The EPA’s Emissions Factors

In one of their recent government publications, “Greenhouse Gas Inventory Guidance for Direct Fugitive Emissions from Refrigeration, Air Conditioning, Fire Suppression, and Industrial Gases”, the EPA laid out their own methodology for emissions factors included in their WebFIRE database.

Activity-based vs asset-based emissions tracking

The EPA’s factors are activity-based emissions factors, which brings up a discussion of what the difference between activity-based vs asset-based emissions tracking is, and the benefits of each.

There is a fundamental difference between activity-based and asset-based facility material tracking. Activity-based facility management tracking approaches focus on work tracking and orders for tracking operational costs related to material transactions.  Asset-based facility management approaches focus on the condition of an asset to meet its intended purpose.

For example, with the activity-based approach, a maintenance employee reports adding 100 LBS of refrigerant to system “0” at site A. On the other hand, with an asset-based approach, a maintenance employee reports adding 100 LBS of refrigerant to a system at Site A.

While being able to report quantifiable numbers is appealing, it does not communicate all possible things. For example, was the 100 LBS in scenario two was added to a system with a different refrigerant type? Or was gas recovered from the system, or did the amount of gas exceed the listed installed capacity for the site or the assets at the site? Essentially, there is nothing to qualify the transaction.

When an asset-based approach is used, you have a better sense of how well your assets will serve their purpose. For instance, if Site A is the highest use building in your region, you know how to prioritize so it gets the proper amount of maintenance investment.

Therefore, at a fundamental level, we believe the EPA’s approach contains flawed methodology in the development of their emissions factors.

More problems with these emissions factors

In addition to using problematic methodology, the EPA’s factors are very broad and do not include proper discrimination for size, region, vintage, material type, or conditions. For example, the EPA suggests that medium and large refrigeration systems leak 35% annually, which is significantly higher than the real world values we see reported as a result of asset-centric, activity-oriented data capture process.  Direct observations and reported data indicate that annual leak rates range from 8-25% depending on a company’s maintenance maturity.

Furthermore, the EPA suggests that 100% of refrigerant remains in a system at the time of shutdown and that rather than looking at the actual charge, users use the full capacity value when determining emissions.  However, from direct evidence, we know that end-of-life capacity is commonly closer to 75% of capacity. The EPA also has recovery efficiency listed at 70% of remaining charge, whereas actual data shows that recovery efficiency is closer to 85-90% of remaining charge.

The EPA took much of this data from the 2006 “IPCC Guidelines for National Green House Gas Inventories.” However, this document seems to have been based on smaller systems and they used a more risk-oriented approach rather than under-reporting. Also, IPCC recognizes that certain refrigerants are ozone-depleting, but that we shouldn’t report on them because they are being phased. This is problematic because it is not showing the true amount of emissions in the atmosphere.

The EPA acknowledges major uncertainty in their material balance approach related to recently installed equipment. Equipment can leak for two or more years before needing a recharge, so emissions over this period are not detected until after they occur.

The Climate Impact of This Methodology

Not only does this specific methodology lead to inaccurate emissions data, but it also leads to our industry having more of a negative impact on climate change.

The misreporting of refrigerant emissions has led to an annual emission rate of 600 Million LBS of refrigerant with an average emissions rate of .9 tons per LB of refrigerant this represents 540 million tons of carbon. Components such as valves and electrical parts often perform more than one function. Failure data for specific applications and non-standardized taxonomy and activity tracking limit the ability of data collections teams to create a standardized approach to the process of data collection.

These deficiencies in failure rate data result in problems applying a standardized leak or emissions rate to an actual simplified design analysis as suggested by the EPA.  These problems associated with acquiring failure rate data and associated leak rates for refrigerant-containing equipment demonstrate the need for reliability-predictions models that do not rely solely on the activity events to create predictive leak and emission rates.


broken wire


The Impact of Faulty Emissions Factors

Many climate change initiatives have already started with this faulty data in mind. Businesses are working toward goals that are built off of problematic methodologies. This means that the way they are moving toward the future may not actually reduce emissions, or reduce them much less than we actually need to.

Countries’ Pledges Built off Poor Data

In a recent article for the Washington Post, Chris Mooney dives into the issue of countries basing their plans for improving the climate on faulty data, including information from emissions factors.

He notes that many countries are making pledges and claims that seem too good to be true. For example, a document from Malaysia says that their trees are absorbing carbon four times faster than similar forests in neighboring Indonesia. This has allowed them to subtract 243 million tons of carbon dioxide from its 2016 inventory, removing 73 percent of emissions from its bottom line.

In an examination of 196 countries reporting to the UN, there was a huge gap in what countries reported in their emissions. This ranges from 8.5 billion to 13.3 billion tons a year of underreported emissions. At the low end, this gap is equal to the annual emissions from the United States. At the high end, it equals the annual emissions from China. Clearly, there is much work to be done in making sure that data is accurate, and it has an impact on climate change.

Rob Jackson, a professor at Stanford University, commented on this. “If we don’t know the state of emissions today, we don’t know whether we’re cutting emissions meaningfully and substantially . . . The atmosphere ultimately is the truth. The atmosphere is what we care about. The concentration of methane and other greenhouse gases in the atmosphere is what’s affecting climate.”

Governments don’t have any clear path forward, though. Alexander Saier, a communications officer at the United Nations, says that they are trying to strengthen the reporting process. He notes, though, “However, we do acknowledge that more needs to be done, including finding ways to provide support to developing country Parties to improve their institutional and technical capacities.”

Missing and Misrepresented Emissions Information

Countries also tend to find ways around reporting all their emissions to appear to be approaching net zero. For example, UN rules allow countries to claim that emissions are being absorbed by land. Large polluters including China, Russia, and the United States are able to subtract half a billion tons of annual emissions using this rule, which allows them to appear more climate-friendly than they really are.

One of the main emissions that are being under reported are fluorinated gases, or f-gases, which includes refrigerants. In some countries, f-gases aren’t being reported on at all. This is a major problem, since they are a top contributor to global warming.

For example, Vietnam reported that its emission of f-gases plunged between 2013 and 2016 to just 23,000 tons of CO2 equivalent. This is 99.8 percent lower than The Post estimated in their own scientific data set using the Earth System Science Data emissions factor. Clearly, depending on what factor you use, there are major discrepancies.

Differing Standards

Part of these discrepancies stem from the way that the UN oversees reporting. Developed countries have one set of standards, while developing countries have another. This is supposed to account for the fact that developed countries contribute more to global warming and have more capacity to be able to report on their emissions, but this ultimately creates a lot of latitude for error. For example, the Central African Republic claims that they are absorbing 1.8 billion tons of carbon dioxide. This is clearly not true, since that would offset the entire carbon emissions of Russia.

The Synthesis Report

Early in 2021, the UN published its synthesis report, forecasting the effect of countries’ climate promises on the environment. However, this report shows numbers 10 billion tons above what countries are actually reporting, showing that we are closer to a better environment than we actually are.

This can all be traced back to underreporting. We know that countries are using emission factors to put together their data. As we’ve outlined, though, there are issues with their methodology and how they are compiling data.

Therefore, it’s no surprise that grand reports that are supposed to guide us toward a better future for the planet are not actually doing this. Without clear data, it’s difficult to create a concrete plan to move forward. Any plan that is created won’t have as much of an impact on the environment as we need.


two hands holding a plant and a globe


Unreliable Pollution Estimates from the EPA

This issue isn’t just a problem for the UN – it’s also an issue at the EPA. In a piece for The Center for Public Integrity, Rachel Leven delves into the problems behind the emissions factors that the EPA has been putting out to the public.

As part of this piece, Leven talks with Jim Southerland, who was hired by the EPA in the 70s to fight air pollution. Southerland developed many of the agency’s emission factors.

However, by the 90s, he was disillusioned with how emissions factors were being used. Instead of being used to provide averages, they were being used for things that should require certain numbers, such as permits for how much pollution facilities could emit.

Even the EPA admits this problem. It rates 62 percent of its factors as “below average” or “poor.” About 17 percent earned grades of “average” or better. Problems include poor accounting practices to problematic risk assessment for rulemaking.


Leven points to the city of Houston as a case study for what happens when faulty emissions factors are used to make policy and fight air pollution.

Houston was using emission factors to guide its ozone-control strategy. This didn’t lead to less air pollution, though – things more or less stayed the same.

The city ultimately needed to pivot. They had been controlling the wrong emissions, and through a study, realized that they needed to be focusing on ethylene. They expanded VOC monitoring and developed new rules to reduce emissions. With this pivot, ozone production rates dropped 50 percent in six years.


Leven also shows how individual facilities cannot rely on emissions factors. Similar to the city of Houston, in a Shell facility in Houston, a study showed that levels of benzene were 448 times higher than what an emissions factor had reported. This ultimately led to Shell needing to pay a $2.6 million fine and spend $115 million to control pollution.

Both these instances show that emissions factors, when relying on faulty methodologies, lead to underreporting, and this has major consequences. On the environmental level, it leads to governments not actually making any progress in fighting global warming. On the corporate level, it leads to fines and public relations nightmares.

Addressing the Problem

The EPA knows that there are problems with their emissions factors and the way that they are being used. According to a spokeswoman that Leven talked to when writing this article, they are executing a plan to improve the science that underlies emission factors and review the estimates more frequently.

However, even while acknowledging the problem, the EPA does not plan to limit what factors can be used for. This means numbers will still be used in permitting and for other uses, even though they contain inaccuracies.

People in industry tend to be fine with this. Many argue that emissions factors are their only data option. Trade groups argue that there should be no fines for using factors, even if they are found to be faulty.

However, public health advocates and others passionate about global warming believe more should be done. Leven quotes Neil Carman, clean air director for the Lone Star Chapter of the Sierra Club in Austin. He states that, “We don’t know what the emissions really are . . . It’s a real Pandora’s box of problems.”

Advocating for Change

Many advocates see emissions factors as giving companies a way out of being truly accountable for what they are putting in the air. They see it as a way around measuring their full impact, especially since emissions factors lead to underreporting.

At trakref, we would agree with this sentiment. We believe that there can be more accurate emissions factors available. Where many companies stand now, though, emission factors are allowing many companies to underreport.

We believe that curbing emissions is what we need to be doing to better our environment, and emissions factors prove time and time again that they are unable to do that.

What to Do Instead

If emissions factors are no good, though, what are companies supposed to do?

As these examples show, we need more accurate ways to show emissions. If companies don’t do this, they are liable to underreport and further pollute the environment, even if they don’t mean to. That’s just the nature of using factors.

Instead, companies need to be properly tracking emissions. These examples also show that once studies and proper tracking were put in place, progress was made. Pollution went down, and companies, countries, and municipalities could figure out a better path forward.

This is where software such as trakref comes in. By using the right software and having the right tools on hand, your company will be able to know exactly what it is putting into the atmosphere and how that is affecting ESG goals.

Track refrigerant using workflows

We built trakref to be easy-to-use for technicians out in the field. We know they already have a lot to worry about, and we wanted to compliment their work – not add more stress onto it.

Through either our app or desktop solution, technicians can enter the inventory they are installing, what types of refrigerant they are using, and other important information. They’ll be guided through workflows that ensure that what they are doing is in compliance at the state and federal levels.

Leak rate detection

Emissions factors often show that you’re leaking less pollutants into the air than you actually are. With trakref’s leak rate detection, you’ll be able to accurately show your leaks and fugitive emissions. You’ll have an accurate understanding of emissions related to refrigeration and be able to report on this.

Track against your goals

Many companies now have specific carbon goals that they want to reach. By relying on trakref software rather than emissions factors, you can accurately track yourself against these goals. Our Scope 1 Emissions Module allows you to input what specific goals you have, and you can see how your actual output stacks up against them.

Investors Want More than Emissions Factors

Of course, we hope the altruistic goal of curbing emissions to protect the planet is enough to motivate you to leave emissions factors behind and turn to better tracking through software. But if that’s not enough, there’s another reason – investors.

In the past decade, investors have wanted more ESG reporting and information to make their decisions. This has gone from a trend to something that will now be required by the SEC – rulemaking to make reporting on Scope 1, 2, and 3 emissions required for publicly traded companies is now moving forward.

If your company is using information from emissions factors to provide this information, you’ll stick out. While the numbers may seem obtuse to some, they are less obtuse to investors who see this data all the time. They’ll be able to pick out if your information looks underreported, and this will put doubt in their minds about the strength of your company.

Having the right data is no longer just about saving the planet – it’s also about making sure you impress the right people and show that your company is in line with others that you’re competing against in the marketplace.

Get in Touch With a Refrigerant Geek

If you’re ready to move away from emissions factors and start tracking your emissions data accurately, get in touch with us today. We’ve been helping people get the data they need for decades, and we’re ready to help you out.

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