Preparing For Mandatory Greenhouse Gas Reporting

Are you ready to tell your constituents that their government created more than 46 billion pounds of global warming-causing greenhouse gases?
by , | March 17, 2010
 

If you weren't watching the Environmental Protection Agency last year, you've missed one of the most exciting turnarounds of a federal agency in a very long while. Like a long-dormant volcano that has suddenly erupted, the EPA sprang back to life on global warming. Within the next 18 months, state and local government executives will be feeling the heat from these changes.

Before last year, the EPA's approach to tracking and regulating the greenhouse gases that cause global warming wavered between apathy and denial. But with the new administration came - in very short order - a favorable Supreme Court ruling that effectively categorized greenhouse gases as a lethal pollutant that could be regulated by the EPA under the Clean Air Act; a greenhouse gas emission reporting rule that impacts thousands of municipalities and businesses; aggressive movement toward a mandatory cap-and-trade system for emissions; and a dramatic but unsuccessful bid to establish a leadership position during the Copenhagen climate summit.

This puts the EPA at the center of a drama that will play out on multiple levels over the next 18 months. And, like it or not, this drama will end up in your backyard.

On the front lines will be any municipalities in the electric and/or solid waste business. Under the EPA's new mandatory reporting rule, all greenhouse gas emissions from electric utilities in 2010 will need to be tracked and reported. Municipal solid waste facilities of a certain size will also need to report. Depending on the scale and sophistication of these operations, the reporting requirements will vary from an annoyance to a serious burden. And failure to comply could bring penalties up to $30,000 a day.

The backyard drama will have a brief intermission as all of the data coming in is crunched. There are some considerations that government executives should think about now - in advance of the mandatory data being reported:

Get ready for the data to be published. If you have never disclosed your government's greenhouse gases before, your constituents may be shocked and alarmed by the data coming from the mandatory reporting rule. Public interest groups will map the data by ZIP code. One of these groups will likely also do the math to turn an easy-to-swallow but hard-to-understand phrase like "2.73 billion metric tons of equivalent carbon dioxide" into an easy-to-understand but hard-to-swallow "6,018,465,308,266 pounds of greenhouse gases that cause global warming." There is a possibility that the initial public shock over this data will turn to anger toward public officials. If you don't think that this will happen, consider how transparency about bonuses has impacted public perception of Wall Street.

Consider stopping any double greenhouse gas reporting. We were told point blank by an executive from a large electric utility that they would be pulling out of their voluntary programs, and instead, report only to the EPA starting in 2010. If a major driver of greenhouse gas emissions in your voluntary reporting relates to what you'll be reporting to the EPA, you could save resources by only reporting once.

Compare your data against any old inventories you've done. If your city or state did a greenhouse gas inventory, it will probably need to be restated historically. Because precise data hasn't been available, nearly all large scale inventories of greenhouse gases have been built using macro estimates, models and broad fuel use assumptions. The mandatory reporting rule will cut through much of the mathematical abstraction by reporting the specific greenhouse gas emissions on a facility level. We predict that the equivalent carbon dioxide totals from the new, more precise greenhouse gas data will be higher than previous models: Our low inventory estimate of 2.73 billion metric tons of ECO2 is more than 15 percent above the EPA's 2006 national inventory estimate for electricity generation and other stationary combustion sources, which comes in at 2.35 billion metric tons.

Prepare for your voluntary agreement goals to be reset. If you are part of a voluntary compliance program like the U.S. Conference of Mayor's Climate Protection Agreement, your emission reduction targets will probably be reset. Greenhouse gas emission targets such as those from the Kyoto Protocol, which is used in the Climate Protection Agreement, have been set using greenhouse gas inventory data as a baseline. If your existing inventory figures are overturned by more precise madatory reporting data, there will need to be a commensurate change in reduction targets. As mentioned above, we predict that the national inventory ECO2 totals are low. This means that the total amount of ECO2 needing to be reduced will grow, emission reduction targets will need be larger and the related cost for reductions will increase.

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