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.