Ohio Environmental Law Blog : Ohio Environmental Lawyer & Attorney : Joseph Koncelik : Frantz Ward Law Firm : Environmental Regulation, Land Use, Compliance : Cleveland, Ohio

Kudos to those in Cleveland  responsible for launching the country's first community based carbon offset fund- the Cleveland Carbon Fund.  It is an innovative approach to offsetting your personal or business carbon footprint.  Richard Steubi's Cleantech blog describes the difference between the Cleveland Fund and other offsetting options:

"There are already several options in the marketplace for interested parties to acquire emissions offsets to mitigate their carbon footprint. However, customers of these services usually do not know where the emission reductions will occur. For instance, if I use a service like TerraPass to offset the emissions from my next airline flight, I don't know exactly where the emission reductions will occur. Looking at the emission reduction projects sponsored by TerraPass, they span the width of the entire U.S."

Similar to other carbon funds, green conscious individuals or businesses can calculate their carbon footprint then make a donation to offset their carbon emissions. However most other funds use donations to purchase renewable energy credits to fund renewable energy projects or carbon credits.  The Cleveland Carbon Fund uses donations to fund  and provide technical support for specific projects right here in Cleveland.   An example of the types of projects funded include:

Compact Fluorescent Lamp (CFL) Installation
 [I]t is estimated that $20,000 from the Cleveland Carbon Fund could fund local community development organizations to install 8,000 CFLs in 1,000 low-income homes across Cleveland. In five years, this initiative would save these homeowners $250,000 and reduce carbon emissions by 2,000 tons at a cost of $5 – $10 per metric ton of carbon reduced.

Showerhead Replacement
Low-flow showerhead valves use half as much water while providing the same level of pressure. According to the Department of Energy, installing these valves saves $11 in water heating every three months...a $30,000 grant from the Cleveland Carbon Fund could fund non-profit organizations to install these valves in more than 200 low-income homes...This project would save Cleveland homeowners almost $10,000 in hot water heating and annually reduce carbon emissions by more than 100 tons at a cost of less than $10 per metric ton of carbon dioxide reduced.

Home Weatherization
For approximately $50,000, the Cleveland Carbon Fund can support more than 20 weatherization projects in low-income neighborhoods across the community, employing many local citizens. Sealing and insulating homes to better retain heat during the winter will save Cleveland homeowners more than $5,000 in energy bills and reduce carbon emissions by 40 tons each year.

If we have learned anything from the first few weeks of the Obama Administration its that climate change, renewable energy and sustainability will be key themes repeated early and often.  Rather than fighting this change, Ohio and Cleveland would be smart to see how they can leverage this massive impending change to grow its economy. 

Innovation and leading will be key to securing green jobs in this difficult economy.  We need to see more proposals like the Cleveland Carbon Fund in order to compete with all the other areas of the country that are actively trying to brand themselves green states and cities. 

(Photo: laszlo-photo/everystockphoto.com)

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On August 20th, the Public Utilities Commission of Ohio proposed rules governing greenhouse gas reporting and carbon dioxide control planning.  Parties wishing to file comments have until September 6th to file comments.

The most interesting aspect of the rule is it proposes to mandate all electric generating facilities in Ohio become participating members in the Climate Registry.  It also mandates electric generating facilities to report report greenhouse gas emissions according to protocols approved by the Climate Registry.  While Senate Bill 221 provided discretion to the PUCO to establish the level of participation in the Climate Registry, the Commission has decided to mandate participation.

I'm sure the Commission will receive comments on their definition of "electric generating facility" covered by the mandatory reporting requirement.  The definition is as follows:

"Electric generating facility" means an electric generating plant and associated facilities capable of producing electricity.

There is no minimum size requirement specified in the proposed rule.  Therefore, it would appear an electric generating facility of virtually any size under PUCO's jurisdiction faces a mandatory reporting requirement.

I would also expect comments from the Utilities that the mandatory reporting requirements should wait until U.S. EPA proposes its mandatory greenhouse gas reporting rule in September.  U.S. EPA's reporting rule will specify required reporting as well as include limitations on the size of the generating unit covered by the mandatory reporting requirement. 

U.S. EPA propose rule will also shine light on the interplay between the Climate Registry and mandatory federal reporting requirements. Perhaps the Commission left themselves some wiggle room by inserting "or as otherwise directed by the Commission" right after the mandate to participate in the Climate Registry.

The rule also requires each owner and operator of a electric generating facility to file an annual report specifying its control plan for both criteria pollutants (NOx, SO2) and for carbon dioxide.  However, the rule lacks any specificity as to what elements must be included in the plan.  The proposed rule requires the environmental control plan include:

"...all relevant technical information on current conditions, goals, and potential actions based upon the current scientific and engineering design capability of any facility...to control emissions of criteria pollutants and carbon dioxide within the parameters of economically feasible best technology."

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In my last post I discussed corporations that are using a vast array of accounting methods to calculate carbon footprints.    An article in the Seattle-Post-Intellegencer discussed variations found in outputs from household on-line carbon footprint calculators.

While US EPA's forthcoming rule will address measuring emissions of greenhouse gases from large industrial sources, it certainly appears there are more areas needing standardization.  I should not be able to cut in half my personal carbon footprint simply by using a different calculator. 

The article was triggered by a University Washington study of household carbon footprint calculators commonly found and used on the web:

A recent University of Washington study found that when the same values were used with 10 different online calculators, the results varied greatly. In one category, the bottom line for a typical American homeowner varied by more than 32,800 pounds of carbon produced per year.

The variation suggests tallies of carbon emissions have been oversimplified to produce a "one-click" solution to an extremely complicated problem -- global warming. Some experts fear calculators suggesting a person plant a few trees to offset driving a gas guzzler may actually discourage needed lifestyle changes that can benefit the planet.

"Everyone assumes that every calculator they use will produce an accurate result, but in reality, there are vast inconsistencies between the calculations being done," said Anne Steinemann, a UW civil and environmental engineering professor who headed the research. "I was really surprised by the magnitude of inconsistency."

The newspaper also did its own research and included a chart showing the dramatic variations.

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Have you measured your company's carbon footprint yet?  Don't worry if you haven't,  in the wild west that is climate change sometimes it pays to wait and see how things shake out.  For instance, who would have thought just picking an accounting method for measuring greenhouse gas (GHG) emissions would be so complicated. 

There is no doubt that quantifying emissions is gaining in popularity.  A recent survey of North American supply chain executives determined that 60% decided to measure their emissions.  Their motivations may be fear of impending greenhouse regulations, compliance with existing requirements, customer demands or sustainability initiatives within their company.

While many executives have decided to measure emissions, not all executives are going about it in the same way.  A recent study of greenhouse reporting and verification methods found that more than 34 different protocols and guidelines for reporting emissions have been used.  Variation occurs even among companies located in countries or states with mandatory greenhouse gas regulations. 

Such variation leads to a great deal of inconsistency and therefore, a lack in comparability between corporations' reports.  There is ever-growing controversy as to whether within various industrial sectors an apples to apples comparison can be made of company footprints or emission reduction targets.

Perhaps things are beginning to take shape, the States have seemed to coalesce around a greenhouse gas accounting method- The Climate Registry.  (The adjacent map shows those states and Canadian provinces who have endorsed the use of the Climate Registry)  However, until US EPA weighs in, you are still risking having to make adjustments to your calculation of GHG emissions.  Fortunately, the sheriff is about to ride into town.

Recently, Congress directed US EPA to publish a mandatory GHG reporting rule, using the Agency's existing authority under the Clean Air Act. (H.R. 2764, Public Law 110-161).  Congress has required EPA to publish a draft rule by September 2008 and a final rule no later than June 2009.  The long gap between draft and final rule will allow for a rigorous public comment period. 

Congress has directed the Rule must address certain key elements, such as:

• Reporting on emissions from upstream (fossil fuel and chemical producers and importers) and downstream sources (large industrial direct emitters)
• Mandatory reporting thresholds
• Frequency of reporting

The EPA is provided discretion to utilize methods already in use and can build upon existing mandatory and voluntary reporting systems, such as:

• Existing reporting for electric generating units under Section 821 of the Clean Air Act
• Federal reporting program (Title IV, Climate Leaders, 1605(b))
• State programs (California, The Climate Registry, RGGI, other State programs)
• Corporate programs (WRI/WBCSD)
• Industry protocols (API Compedium, CSI Protocol, or International Protocols)

If you're not familiar with all of the references to various protocols that's okay.  It may be prudent to wait until EPA at least releases its draft reporting rule to get an idea of how this shakes out. 

Perhaps EPA will say that use of the Climate Registry method is acceptable for purposes of its rule, in essence endorsing the standard. Due to the number of states and provinces already backing the Registry, that may be very likely.  However, what if EPA decides to build upon or modify requirements?

Keep in mind that even if you wait until September you still risk EPA will make changes during the public comment period.   Companies and organizations that have invested in a certain protocol are going to fight hard to see the EPA rule endorse it.  But in my opinion it would be a grave mistake for EPA to try and avoid controversy by not picking any winners.  Standardization is a must, without it there will always remain issues of inconsistency.

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