GHG Accounting – Page 10

Implementation of California’s Cap & Trade Program Faces Potential Delay after Court Ruling

In a decision issued on March 18, 2011, a California Superior Court judge threw up a roadblock to the implementation of California’s cap-and-trade program by suspending the implementation of A.B. 32, the state’s landmark climate change law on the grounds that the California Air Resources Board (CARB) failed to properly consider alternatives to a cap-and-trade system. While the Court upheld the validity of CARB’s Scoping Plan for implementing A.B. 32, thus saving CARB from having to revise the Scoping Plan, it found flaws with CARB’s environmental review of the Scoping Plan under the California Environmental Quality Act. As a result, not only has the proposed cap-and-trade program been put on hold, but at risk are other elements of the Scoping Plan, including the state’s low-carbon fuel standard and a 33% renewable portfolio standard for electricity by 2020. In his ruling, Judge Ernest Goldsmith of San Francisco Superior Court said that the CARB “seeks to create a fait accompli by premature establishment of a cap-and-trade program before alternatives can be exposed to public comment and properly evaluated.”

The ruling by Judge Goldsmith does not prohibit the CARB from adopting cap-and-trade or require the delay of the scheduled start of date of January 1, 2012, but Judge Goldsmith said that CARB must first analyze other options (such as a carbon tax) and explain why it did not choose such options. Given the tight timeline this year for finalizing the details of California’s climate change plan, the ruling represents a potentially significant hurdle in the timely implementation of the state’s greenhouse gas emission reduction initiatives. The CARB’s spokesperson, Stanley Young, expressed dismay at the scope of the ruling, which requires the board to conduct an environmental review and invite public comment before taking further steps to implement the law. Mr. Young has indicated that the CARB will appeal the decision, which could result in pushing back the cap-and-trade program’s January 1, 2012 start date. An alternative is for the CARB to seek a stay on the ruling that will allow it to implement the climate policies as planned until a final verdict is issued. Also, the CARB could complete the necessary analyses as quickly as possible, but the results of this approach would be uncertain. For example, if the CARB is unable to satisfy the court’s concerns by October 2011 – which is the key deadline for adopting cap-and-trade regulations – this would most likely put the January 1, 2012 start date at risk. If California’s cap-and-trade program is delayed, it is likely that other WCI jurisdictions such as B.C., Ontario and Québec, will also delay the implementation of their cap-and-trade programs until such time as California begins trading.

A.B. 32 was passed in 2006 and requires the state to reduce greenhouse gas emissions to 1990 levels by 2020. The legal challenge to California’s cap-and-trade program was brought by environmental justice groups (the Association of Irritated Residents and other groups) that consider the plan too weak. In particular, they argued that the cap-and-trade program would result in increased pollutants in poor and non-white communities. More mainstream environmental groups, however, have supported cap-and-trade and stayed out of the legal action.

The next likely step is that a Writ of Mandate will be filed within 10 days of the March 18 decision. The Writ is the plaintiffs’ interpretation of the decision and will include their preferred remedies. The judge will then decide on the final remedy. Any appeal to that decision would have to be filed within 60 days from the date the decision was entered.

At this stage, it is unclear what the court-ordered remedy will consist of and whether it will affect all work on measures to reduce greenhouse gas pollution – observers indicate that it most likely it will not. Following the decision, the Environmental Defense Fund issued a conciliatory statement that perhaps best captures the intent of the parties: “It is clear from examining arguments of both parties before the Court that CARB and the environmental justice groups bringing the action against the State are committed to improving California’s environment and fighting climate change and do not intend to bring AB 32 work to a halt.” Stay tuned as this story evolves.

Revisions to BC Reporting Regulation now in force for 2011 Reporting Year

Recent amendments made to BC’s greenhouse gas Reporting Regulation have come into effect for 2011 calendar year emission reports (to be reported by March 31, 2012)

The amendments made in order 849 dated 17th of December 2010 to BC’s greenhouse gas Reporting Regulation have come into effect for 2011 calendar year emission reports (to be reported by March 31, 2012). These amendments include:

Establishment of a third class of reporting operation – electricity import operation – for the purpose of including imported electricity under the regulation.
Establishment of a reporting-only class of emissions for the purpose of including aboveground coal mine fugitive emissions, along with mobile equipment and carbon dioxide from Schedule C biomass sources.
Miscellaneous improvements including: (i) addition of further requirements to ensure that changes between methods on the part of reporting operations will result in improved emissions estimates; (ii) clarification on handling of terminals/storage tanks; (iii) addition of red liquor to Schedule C; and (iv) an update of quantification method references to incorporate new and revised quantification methods developed by the Western Climate Initiative.
Various changes to data to be reported, including: (i) addition of Income Tax Act business numbers, DUNS and Bradstreet numbers to reports; and (ii) addition of process flow diagrams to reports starting in 2012.
Clarifications have been made to site visit requirements for linear facility operations and changes have been made to the required contents of verification statements.

Additional updates to the Reporting Regulation may be introduced by the government based on the proposed Emissions Trading Regulation and Offsets Regulation, which are expected to be finalized in 2011. These changes could include further reporting-only sources, additions to the Schedule C list of biomass, and additional verification and compliance requirements.

Study Finds that Lowering Levels of GHG Emissions can Increase a Company’s Stock Value

A recent study by researchers at the University of California (Davis and Berkeley) and the University of Otago in New Zealand entitled “The Relevance to Investors of Greenhouse Gas Emission Disclosure” has found that the amount of greenhouse gas (GHG) emissions a company produces and whether a company discloses their emission levels or not has a significant effect on the value of the company’s stock. In particular, the researchers found that the greater the GHG emissions, the lower the value of a company’s stock. Likewise, lower emission levels lead to higher stock values, all other factors being equal. Even if companies do not disclose this information, GHG emission levels are estimated by investors themselves, resulting in an even stronger risk discount to the stock value for high level emitters. This trend is particularly strong in energy intensive industry sectors. The study was led by Paul Griffin, a professor in the University of California, Davis Graduate School of Management.

Professor Griffin and his colleagues also discovered that markets respond almost immediately when a company releases information on their GHG emissions, with stock values responding the same day as the disclosure. “It really does appear to be a valuation factor,” Professor Griffin says. “Greenhouse gas emissions are important to investors in assessing companies.”

The findings bolster the arguments of investor groups, environmental advocates and watchdog organizations that have been seeking greater disclosure of company actions that affect climate change. The U.S. Securities and Exchange Commission (SEC) does not require all companies to report GHG emissions, but companies are required to disclose any information that is considered material to stock values. The findings of this study strongly suggest that GHG emissions data is relevant information to investors, therefore it could be argued that all public companies should disclose their GHG emissions to comply with SEC requirements. Approximately 50% of large U.S. firms report GHG emissions through the Carbon Disclosure Project.

The researchers analyzed four years of data (from 2006-2009) on firms listed in the Standard & Poor’s 500, and five years of data (2005-2009) for the top 200 publicly traded firms in Canada. While the researchers found the link between stock values and GHG emissions to hold true in most industries, the correlation was strongest for energy companies and utilities. According to Griffin, “after controlling for normal valuation factors like assets and earnings, we found the value of stocks to be a function of greenhouse gas emissions”.

Investors care about GHG emissions because markets are forward looking. Professor Griffin has indicated that in this case, investors are anticipating a time when companies will face increased costs for climate change mitigation, regulation and taxes.
The full study can be downloaded at Link.

ICLEI seeks public input on draft Community-Scale GHG Emissions Accounting and Reporting Protocol

In response to the needs of its member local governments, ICLEI-Local Governments for Sustainability USA (ICLEI was originally established as the International Council for Local Environmental Initiatives) has released a draft Community-Scale GHG Emissions Accounting and Reporting Protocol for public comment.

Rationale for the Community Protocol

Local governments are increasingly looking to create policies that will reduce emissions from the activities of their residents, businesses, and visitors. The emissions reduction process begins with identifying primary sources of emissions and quantifying the scale of emissions from these sources. By establishing standards for community-scale inventories, communities can ensure the consistency and quality of their inventories. In addition, such standards will allow for accurate monitoring of progress against emissions targets, and provide standard guidance as local governments pursue environmental review, inventory certification and other relevant processes in their day-to-day operations. A national standard will form the foundation of future climate actions, thereby enabling communities to address the challenges of climate change more effectively.

The Community Protocol will complement the Local Government Operations Protocol and serve as a U.S. Supplement to the International Emissions Analysis Protocol. The draft framework is available for review online.

California Adopts Cap & Trade Program after Landmark Vote

In a landmark 9-1 vote on December 16, 2010, California’s Air Resource Board (ARB) voted to adopt the first large-scale cap-and-trade program in the U.S.

In a landmark 9-1 vote on December 16, 2010, California’s Air Resource Board (ARB) voted to adopt the first large-scale cap-and-trade program in the U.S. This vote represents the culmination of an eventful year for California’s AB 32 legislation, which aims to reduce the state’s greenhouse house gas emissions to 1990 levels by 2020. In California’s general elections held in November 2010, AB 32 survived a ballot measure that would have indefinitely delayed the program. California’s progress towards cap-and-trade comes as federal efforts to establish a nation-wide emissions trading program have stalled in Congress.

Under the proposed California cap-and-trade rules, the state would initially give away allowances to regulated industries. In later years, California would auction allowances. Industries that could show the regulations were putting them at a significant competitive disadvantage to companies in other, less carbon-constrained, jurisdictions could qualify for additional free allowances. The proposed rules would establish a $10 per metric ton auction floor price on carbon. Regulated emitters would be able to purchase carbon offsets, which are expected to trade at a discount to emission allowances, to comply with 8% of their annual emission obligations.

Offsets under the California Program

In addition to the regulations for the cap-and-trade program, ARB adopted four protocols that will be used to generate offsets for compliance, marking the first time forest carbon offsets will be included as a part of a compliance carbon market.

Offsets will come from early action efforts, compliance offsets and a category known as sector-based offsets, which will come from programs managed in developing countries. Early action offsets include those from the 2005-2014 vintages of Climate Action Reserve (CAR) credits from projects in methane digestion, destruction of ozone depleting substances, forestry and urban forestry.

In anticipation of California’s cap-and-trade program, the carbon market has responded with a jump in offset prices. Analysts note that offset prices have doubled from about $4 per ton of to $8 per ton amid higher volumes of trading in recent weeks.

Analysts have also predicted a shortfall in the supply of offsets. CAR projects that the ARB-approved protocol types will be able to generate approximately 30 million tons of credits through 2014, which credits can be used in the California program. However offset demand is projected to exceed 200 million tons through 2020. Now that there is regulatory certainty, the market must now work to fill the gap between offset supply and demand.

New Mexico Approves its Cap-and-Trade Program

In other news, New Mexico narrowly approved its cap-and-trade program in early November 2010 as well as the state’s participation in the regional Western Climate Initiative market. These measures will not go into effect unless other U.S. states or Canadian provinces move ahead with similar systems for capping emissions. The New Mexico program would regulate approximately 63 large industrial sources.

UK Study finds that Measuring and Reporting GHG Emissions Delivers Cost Savings and Business Benefits

A research study released by PwC and the Carbon Disclosure Project (CDP) found that voluntary reporting of greenhouse gas (GHG) emissions is helping to cut costs and improve relationships for businesses.

On November 30, 2010, a research study released by PwC and the Carbon Disclosure Project (CDP) found that voluntary reporting of greenhouse gas (GHG) emissions is helping to cut costs and improve relationships for businesses. The research, commissioned by the UK Department for Environment, Food and Rural Affairs (Defra), surveyed more than 150 large companies and found that over 50% said the benefits of GHG reporting outweigh the costs involved. Participating businesses said the emission reports initiated board level interest in environmental issues and drove environmental change company-wide. Furthermore, 72% said they now have a corporate climate change strategy designed to reduce GHG emissions.

Measuring emissions cost less than £50,000 (approximately CAD $80,000) for 65% of the companies surveyed and approximately 14% of companies calculated energy cost savings of more than £200,000 a year (approximately CAD $320,000) as a result of GHG accounting initiatives. Against quantifiable business costs and benefits, 60% of companies found there to be a net cost of reporting, but when considering wider benefits such as reputation and consumer awareness, 53% of companies said there was a net benefit. Companies also said the distinction between voluntary and mandatory reporting is already blurred, with schemes such as CDP becoming semi-mandatory.

Joanna Lee, Chief Partnerships Officer at CDP commented that: “Reporting drives the action of measuring, helping companies to identify opportunities for emission reductions. It also helps companies set meaningful and achievable reduction targets, as well as advancing better risk management and increased awareness of new market opportunities.”

The study has been submitted to the UK Parliament as part of a wider analysis commissioned to inform the government’s decision on mandatory reporting. A decision is expected in early 2011.

Creating or Buying Credits – Financing Your Next Cool Move!

Offset credits are created through the implementation of projects that result in emission reductions or removals beyond what would have been done under normal business activities (the so-called “business as usual” baseline). One credit represents the reduction or avoidance of emissions of one tonne of carbon dioxide equivalent (CO2e). Once offset credits are created and certified by accredited third parties, they can be sold to buyers in the market (usually regulated entities that need to meet certain compliance obligations). The system described above is often referred to as a “compliance market”. Offset credits can also be sold in the voluntary market to non-regulated entities who are looking to reduce their carbon footprint voluntarily.
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Climate Change mitigation strategies aimed at reducing greenhouse gas (GHG) emissions can take any number of different forms. The most drastic one would be to simply make the emission of GHGs illegal. This is an extreme example, one that would not be a viable option in an economy based on industrial growth. A more viable options that have been implemented by some, and considered by others, to bring about GHG reductions are market mechanisms. Market mechanisms are designed to utilize market forces to change behaviour, thus leading to reductions in emissions.

Driving Behavioural Change

The most important aspect of market mechanisms is to drive behavioural change – whether by individuals, governments, companies or others – in the direction of low carbon or less emissions-intensive technologies and processes. Offset credits are one of the instruments that have been employed in the carbon market to reduce emissions. However, the market mechanisms that have emerged so far vary quite a bit in their mechanics. As a result, the offset credits generated in these markets will vary accordingly.

How does a carbon market work?

In a so called carbon market (this usually encompasses all greenhouse gases); regulated entities can buy or sell allowances or permits for emissions, or credits for reductions in emissions of specified pollutants. Carbon trading can be done at a regional, national or international level. Under a typical carbon trading regime, regulated emitters will be allocated a limited number of emissions. Emission allowances may be created by a regulating entity, through emissions reduction activities or both. These emission allowances can be auctioned or given away for free. Once initially allocated or created, emission allowances are fully fungible commodities, meaning they can be bought, sold, traded or banked for future use. Often, carbon markets will also allow the use of offset credits as a compliance tool. Allowances effectively set a price on GHG emissions while credits set a cost reward for the investment made to reduce or avoid GHG emissions.

Creating Offset Credits

Opportunities in the Carbon Market

You can purchase credits to offset unavoidable GHG emissions to either meet your own carbon neutral targets or to comply with regulatory emission requirements. You have to make sure the credits you buy are appropriate for the purpose you want to use them for. GHG Accounting can help you make the right decision and evaluate this in the most cost-effective way.

You can also create offset credits. Offset credits can help generate revenue that you can put towards your next efficiency investment. Do you have to replace old machinery, installations or boilers? Or are you changing the way you deal with waste products, energy and emissions? Even if you have done so recently, your actions may still qualify as an emissions reduction project and can earn you real cash!

What GHG Accounting Can Do For You

The effective accounting and management of greenhouse gas (GHG) emissions requires unambiguous, verifiable specifications. This will ensure that a tonne of carbon equivalent can be consistently calculated. To that end, an internationally agreed upon standard for measuring, reporting and verifying GHG emissions was introduced in 2006 by the International Organization for Standardization (ISO) and is referred to as ISO 14064. GHG Accounting Services Ltd. provides specialized GHG consulting and accounting services, including (i) emissions reporting and footprint inventory quantification, (ii) emissions reduction project planning, and (iii) quantification, documentation and carbon offset credit registration.

Manitoba begins Consultation on Proposed GHG Legislation

The Manitoba government has launched a public consultation period to gather input on proposed cap-and-trade laws aimed at reducing greenhouse gas (GHG) emissions. The consultation is part of Manitoba’s commitment, announced in December 2009, to move forward on enabling legislation to create a cap-and-trade system.

In June 2007, Manitoba joined the Western Climate Initiative (WCI). It is expected that Manitoba’s system would integrate with the WCI, meaning that Manitoba will be able to participate in the WCI trading system with BC, Ontario, Québec, California as well as other several U.S. states. The WCI’s goal is to reduce GHG emissions in the region by 15% below 2005 levels by 2020.

In 2008, Manitboa’s GHG emissions was 21.9 megatonnes of carbon dioxide equivalent (CO2e) or approximately 3% of Canada’s total GHG emissions. Manitoba’s GHG emissions profile is unique among Canadian jurisdictions. Unlike other Canadian provinces whose GHG emissions come from a small number of large emitters, the majority of Manitoba’s GHG emissions come from many smaller emitters across a wide range of sectors.

Manitoba’s proposed cap-and-trade program would affect approximately 18 emitters that release more than 25,000 kilotonnes each of GHGs per year. Another group of about 36 emitters that each release 10,000 kilotonnes of CO2e per year or more (but less than 25,000 kiltonnes) would only be required to report their emissions.

According to data from Environment Canada, in 2008 the Koch Fertilizer plant in Brandon was the largest emitter in Manitoba, followed by Manitoba Hydro, Winnipeg’s Brady Road Landfill, TransCanada Pipelines and HudBay Minerals.

Comments on the proposed cap-and-trade program can be made online through the Manitoba Conservation Department website until March 15, 2011.

Accounting for your Footprint / GHG Inventory

A fundamental key to effectively managing your business risk and cost in an increasingly carbon-constrained world is an understanding of your organization’s carbon footprint, which covers emissions generated by your products and supply chain. In order to calculate your carbon footprint, an analysis of your organization’s GHG inventory is essential. A “carbon footprint” represents a measure of the total amount of GHG emissions that are directly and indirectly caused by an activity, organisation or is accumulated over the lifecycle of a product. The carbon footprint captures activities of individuals, communities, companies, processes, or industry sectors and takes into account all direct and indirect emissions. A carbon footprint can be broken down into two parts, the primary footprint and the secondary footprint.
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What is considered “green” or not has always had, and will always have, different meanings depending on a particular point of view as well as the point in time. At the beginning of the green movement, issues such as forest conservation, protection of wildlife and recycling were the focal points. However this has evolved to encompass more comprehensive strategies which we now understand are required to enable meaningful change. These strategies include more holistic approaches to sustainability, biodiversity and climate change. One of the most interesting things in recent years has been the realisation that these strategies make good business sense and result in positive impacts. Examples of these positive impacts include better yields due to crop diversity, lower energy costs due to energy savings, and lower risks and costs associated with having a smaller carbon footprint.

A fundamental key to effectively managing your business risk and cost in an increasingly carbon-constrained world is an understanding of your organization’s carbon footprint, which covers all greenhouse gas (“GHG”) emissions generated by all human direct or indirect activities within the boundaries of direct (Scope 1) or indirect control (Scope 2) of your organisation. In order to calculate your carbon footprint, an analysis of your organization’s GHG inventory is essential.

What is a “Carbon Footprint”?

A “carbon footprint” represents a measure of the total amount of GHG emissions that are directly and indirectly caused by an activity, organisation or is accumulated over the lifecycle of a product (Product footprint). The carbon footprint captures activities of individuals, communities, companies, processes, or industry sectors and takes into account all direct and indirect GHG emissions. A carbon footprint can be broken down into two parts, the primary footprint and the secondary footprint.

The primary footprint is the sum of direct GHGemissions and includes activities such as energy consumption and transportation.

The secondary footprint is the sum of indirect GHG emissions from the entire lifecycle of products used by an individual or organization.

Although carbon footprints are reported in tons of carbon dioxide equivalent (CO₂e) emissions, they actually represent a measure of total GHG emissions. GHGs that are regulated include CO₂, nitrous oxide, methane, hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride. CO₂ is used as the reference gas against which the other GHGs are measured and the impact of all GHGs is measured in terms of equivalency to the impact of CO₂by way of global warming potentials. For example, methane is a far more potent GHG than CO₂, so one metric tonne of methane is measured as 21 metric tons of carbon dioxide equivalent, or CO₂e.

The accurate calculation of an organization’s carbon footprint is important in ensuring that GHG emissions are not under-counted or double-counted, particularly where emission reductions will be used in carbon trading and carbon off-setting transactions. A careful review of a organization’s methodology for calculating its carbon footprint will play a significant role in reducing the risks inherent in carbon trading and carbon off-setting, as well as ensure the credibility of carbon transactions.

GHG Inventories

A GHG inventory is a breakdown of emissions by activity for an organization, expressed in terms of CO₂e. GHG inventories provide the basis for (i) identifying organizational, geographic, temporal and operational GHG inventory boundaries, (ii) identifying all direct and indirect emissions sources, and (iii) determining appropriate methods to calculate emissions through protocols.

The effective accounting and management of carbon requires unambiguous, verifiable specifications. This will ensure that a tonne of carbon can be consistently calculated. To that end, an internationally agreed upon standard for measuring, reporting and verifying GHG emissions was introduced in 2006 by the International Organization for Standardization (ISO) and is referred to as ISO 14064.

ISO 14064 Standard

ISO 14064 consists of three standards, which provide guidance at the organizational and project levels, as well as for validation and verification:

ISO 14064-1 specifies the requirements for designing and developing GHG inventories.
ISO 14064-2 sets out requirements for quantifying, monitoring and reporting emission reductions and removal enhancements from GHG projects.
ISO 14064-3 sets out guidance for conducting GHG information validation and verification.

What GHG Accounting Can Do For You

GHG Accounting Services Ltd. (GHG Accounting) provides specialized GHG consulting and accounting services, including (i) emissions reporting and footprint inventory quantification, (ii) emissions reduction project planning, and (iii) quantification, documentation and carbon offset credit registration.

WCI issues Second Harmonization Package for GHG Reporting Requirements for Canadian Jurisdictions for Consultation

The Western Climate Initiative (WCI) issued for stakeholder review a second harmonization package for reporting requirements for Canadian jurisdictions.

On October 29, 2010, the Western Climate Initiative (WCI) issued for stakeholder review a second harmonization package for reporting requirements for Canadian jurisdictions that builds upon the previously released Harmonization of Essential Requirements for Mandatory Reporting in Canadian Jurisdictions with the WCI Essential Requirements for Mandatory Reporting and the EPA Greenhouse Gas Reporting Program (which contains the WCI’s proposal for harmonizing the existing WCI Essential Requirements for Mandatory Reporting for use in Canadian jurisdictions). Comments on the second harmonization package are due by November 24, 2010.

The second harmonization package contains the WCI’s proposal for new quantification methods for five remaining sources: magnesium production, electronics manufacturing, underground coal mining, petroleum and natural gas systems, and natural gas transmission and distribution. The proposed WCI essential requirements are consistent with those of the U.S. Environmental Protection Agency, but are appropriate for use in the Canadian jurisdictions. It is expected that WCI jurisdictions in Canada will implement the harmonized essential requirements through their reporting regulations.

The second harmonization package is available online link.