Comments by the Pew Center on Global Climate Change Regarding Interim Final, General Guidelines for the Voluntary Reporting of Greenhouse Gases (1605(b)) Program

June 27, 2005

These comments by the Pew Center on Global Climate Change are written in response to the notice of inquiry by the U.S. Department of Energy (DOE) regarding the “Interim Final, General Guidelines for the Voluntary Reporting of Greenhouse Gases (1605(b)) Program [1]” (70 Fed. Reg. 15169 (March 24, 2005)). The Pew Center appreciates the opportunity to comment on this important issue.

The Pew Center previously submitted comments in response to the notice of inquiry by the U.S. DOE regarding “Voluntary Reporting of Greenhouse Gas Emissions, Reductions, and Carbon Sequestration” (67 Fed. Reg. 30370 (May 6, 2002)), as well as the “General Guidelines for Voluntary Greenhouse Gas Reporting; Proposed Rule” (68 Fed. Reg. 68204 (December 5, 2003)). While some of the issues raised in previous comments have been addressed in the Interim Final Guidelines, many significant points have not. The Pew Center considers the issues reiterated below to be essential for the establishment of a successful program to reduce U.S. greenhouse gas emissions.

Mandatory reporting

The Pew Center believes that a mandatory GHG reporting and disclosure program is the logical next step in any effort to address climate change. Even a voluntary emission reduction program requires mandatory reporting in order to determine the overall efficacy of the voluntary effort.

Absolute Reductions in Emissions vs. Reductions in Emissions Intensity

While we think that the reporting of emissions intensity data would be interesting, the emissions reduction picture would more transparent and helpful if absolute emissions reduction data were published alongside intensity data.

Entity boundaries

We appreciate the effort to clarify the definition of an “entity” to be used in entity-wide reporting. However, the fact that reporters retain the flexibility to establish their own approach to entity definitions—rather than requiring reporting at the highest (parent company) level in the U.S.—is likely to provide a skewed view of true entity-wide emissions and make comparison across firms impossible. Additionally, a future mandatory program might be based on the emissions of individual facilities within entities, therefore that information would also be useful to incorporate into this system.

Registering of Activities Prior to 2003

Perhaps of greatest concern is the limitation of registered reductions to post-2002 activities. Under the new two-tiered guidelines, entities may report (but not register) emission reductions achieved prior to 2003. Reductions that were reported to 1605(b) before 2003 could not earn registration status, even if the entities met the new guidelines. The DOE’s decision to distinguish between reductions achieved prior to 2003 and reductions achieved from 2003 is counterproductive and arbitrary. Not only would real, verifiable reductions that occurred before 2003 not be recognized under the proposed system, but entities would have no assurance that a future revision process would not similarly fail to recognize post-2003 registered reductions. While we understand the desire to measure progress toward the President’s goal of reducing emissions intensity 18% from 2002 levels, allowing entities to register reductions that occurred before 2002 would not detract in any way from the ability to measure reductions that have occurred since 2002.

The Pew Center urges that entities be able to register pre-2003 emissions reductions so long as they meet all other requirements of the revised, more stringent 1605(b) guidelines. Many companies have taken responsible actions to curb their GHG emissions and undertake GHG reduction projects over the last decade, due to concern about climate change impacts and in response to the United Nations Framework Convention on Climate Change and various U.S. voluntary programs such as this one that have encouraged early action. A number of these firms acted in good faith reliance on representations from previous government statements suggesting these actions would be rewarded—or at least not punished. These companies should receive credit for their early action. A GHG reporting program should make it possible for such entities to register (and receive baseline protection for) emission reductions and offsets implemented since 1990, so long as the information is certified by the reporting entity and is reported under the established reporting standards. Companies should be able to select any base year in this timeframe for which their emissions are well documented and verifiable.