GHG emission reduction – GHG Accounting

Global Investors Look to Spur Action on Climate Change

At the recent UN Climate Summit in New York, global investors frustrated by the lack of policy progress on climate, issued a call to action through two initiatives: (1) 2014 Global Investor Statement on Climate Change, and (2) Montreal Carbon Pledge.

2014 Global Investor Statement on Climate Change
The 2014 Global Investor Statement on Climate Change has been signed by 354 investors with more than $24 trillion in assets, which represents an important contribution by the global investment community to support the UN Climate Summit and encourage strong domestic and international climate and clean energy policies. The statement sets out the steps that institutional investors (both asset owners and asset managers) can take to address climate change, and calls on governments to support a new global agreement on climate change by 2015 in addition to national and regional policy measures. By articulating their concerns, the signatory investors highlight the climate risk within the context of global investment:
“We are particularly concerned that gaps, weaknesses and delays in climate change and clean energy policies will increase the risks to our investments as a result of the physical impacts of climate change, and will increase the likelihood that more radical policy measures will be required to reduce greenhouse gas emissions. In turn, this could jeopardise the investments and retirement savings of millions of citizens.
There is a significant gap between the amount of capital that will be required to finance the transition to a low carbon and climate resilient economy and the amount currently being invested. For example, while current investments in clean energy alone are approximately $250 billion per year, the International Energy Agency has estimated that limiting the increase in global temperature to two degrees Celsius above pre-industrial levels requires average additional investments in clean energy of at least $1 trillion per year between now and 2050.
This Statement sets out the contribution that we as investors can make to increasing low carbon and climate resilient investments. It offers practical proposals on how our contribution may be accelerated and increased through appropriate government action.”
Now that policy makers have been called on to consider the recommendations in the 2014 Global Investor Statement on Climate Change, the investors are looking forward to a dialogue about the policy frameworks needed to catalyze investment in the clean energy, low carbon future.

Montreal Carbon Pledge
In another initiative, a number of the world’s largest institutional investors (representing more than US$75 trillion in investable assets) launched the Montreal Carbon Pledge at the annual conference of the UN-supported Principles for Responsible Investment (PRI) in Montreal. By signing the Montreal Carbon Pledge, investors commit to measure and publicly disclose the carbon footprint of their investment portfolios on an annual basis. Signatories will be accepted until September 2015. Overseen by PRI, the Montreal Carbon Pledge aims to attract US $3 trillion of portfolio commitment in time for the United Nations Climate Change Conference in December 2015. It also allows investors to formalize their commitment to the goals of a recently introduced Portfolio Decarbonization Coalition, co-founded by the United Nations Environment Programme Finance Initiative.
The Montreal Carbon Pledge represents an important first step to measuring and managing the long-term investment risks associated with climate change and carbon regulation. By measuring their carbon footprints, investors will be able to quantify the carbon content of their portfolios. A growing number of investors, including Etablissement du Régime Additionnel de la Fonction Publique (ERAFP), AP4, London Pensions Fund Authority (LPFA) and VicSuper, have already taken steps to measure the carbon footprint of their investments. 78% of the largest 500 publicly listed companies now report their carbon emissions. PRI will manage the online portal where investors can endorse the Montreal Carbon Pledge. In particular, the portal will enable investors to report the size of their portfolio carbon footprint commitment and any associated carbon reduction targets. Business leaders highlighted the importance for investor to understand their carbon risk in order to reduce their risk exposure:
“There is a perfect storm of reported carbon data, reliable portfolio carbon measurement tools and low carbon investment solutions. This makes it possible for investors to understand and act to reduce their carbon exposure like never before.” (Toby Heaps, CEO of Corporate Knights)
“It is hard to dispute that carbon is a risk, so how can we fulfil our duty of trust if we don’t implement the systems necessary to assess this risk in order to reduce it and, worse still, having measured the risk, we don’t disclose it to stakeholders.” (Philippe Desfossés, CEO of ERAFP)

Regulatory Additionality

Regulatory additionality is a quality requirement for an emission reduction to be recognized as such.

In order for an emission reduction to be recognized, a project proponent must provide evidence that the project activities and all equipment and substances involved in the achievement of the emission reduction are beyond what is required based on applicable regulatory requirements. Only those emission reductions that are achieved beyond regulatory requirements are considered additional and therefore meet the regulatory additionality requirement test. Reductions that only meet the regulatory required levels are not considered to be real emission reductions.

U.S. Consumers are taking into account companies’ actions on climate change when purchasing

According to a recent report from the Yale Project on Climate Change Communication and the George Mason University Center for Climate Change Communication, since 2008, approximately 25% percent of U.S. consumers have either rewarded or punished companies for those companies’ actions related to climate change. The report, “Americans’ Actions to Limit Global Warming in September 2012” (available online), indicates that a significant portion of the consumer market continues to care about the position of companies on climate change. The report also concludes that individuals who have not used purchasing power to either reward or punish companies in the past year plan to increase personal acts of consumer activism in the next year.

The report indicates that in the 12 months leading up to the September 2012 survey, about one in three adults rewarded a company that took steps to reduce emissions. In addition to rewarding companies for taking actions to reduce climate change impacts, 24% of those surveyed in September 2012 indicated that they had at some point in the past year chosen not to purchase products by companies that oppose steps to reduce climate change.

When asked to contemplate future behavior, 52% of individuals surveyed expressed the intent to either reward or punish companies sometime in the next year for the companies’ action or inaction to reduce climate change. Since researchers from Yale and George Mason began collecting data four years ago, slightly more than half of Americans have consistently reported plans to use purchasing power to either reward or punish companies. In November 2008, consumers indicated the greatest willingness (58%) to either buy or not buy based on a company’s actions on climate change. In the economic recession of 2010, willingness to utilize purchasing power to support global warming action fell to 51%. Since then, consumer support for utilizing purchasing power has remained at just over half of the surveyed American adults.

The Yale and George Mason researchers also studied three other prongs of climate actions by citizens: (1) saving energy, (2) citizen behavior, and (3) communication behavior. Even though a majority of American adults report that they always or often set their thermostats below 68 degrees and take other actions like replacing traditional light bulbs with compact fluorescent light bulbs, the researchers noted a decline in Americans’ belief that certain energy-saving actions can reduce climate change. Americans are less confident today than four years ago that their individual actions will reduce their contribution to climate change. While Americans may be less optimistic about their individual impact on global warming, the report’s authors observed that a growing number of Americans say they contacted a government official in the past year to support mitigation of climate change. In the next year, the report indicates that more Americans intend to urge government officials to take action on climate change.

Overall, the Yale and George Mason polling data indicate that Americans continue to be concerned about global warming and are willing to use political and consumer activism to push for action on global warming.

Ontario Ministry of Environment seeks input on Greenhouse Gas Discussion Paper

On January 21, 2013, the Ontario Ministry of the Environment (MOE) released a discussion paper entitled Greenhouse Gas Emissions Reductions in Ontario. The purpose of the paper (available online): is to support discussions and gather feedback on the development of a greenhouse gas (GHG) emissions reduction program. In addition, these discussions will elicit information to support Ontario’s intention to obtain equivalency with the developing federal greenhouse gas regulations in certain sectors (including natural gas‐fired electricity generation), meaning that Ontario industries will not be subject to duplicate requirements.

In 2007, Ontario introduced its Climate Change Action Plan which includes the following GHG emissions reduction targets:

6% below 1990 levels by 2014,
15% below 1990 levels by 2020, and
80% below 1990 levels by 2050.

Ontario estimates that current initiatives to reduce greenhouse gas emissions will deliver 60% of the reductions needed to reach the 2020 reduction target. While a GHG emissions reduction program alone will not close the gap, it will play an important role in moving Ontario towards its goal of being 15% below 1990 emissions levels by 2020.

The program elements presented for discussion in the paper have been developed based on a set of key principles aimed at balancing Ontario’s economic and environmental interests. These principles include:

Achieving absolute reductions in greenhouse gas emissions in a cost‐effective way that considers competitiveness and supports achieving equivalency with the federal government.
Simplicity, consistency, transparency and administrative efficiency.
Striving to treat sectors and facilities equitably.
Taking into account early action by industry leaders.
Using accurate and verified emissions data to support policy development.
Promoting development and deployment of clean technologies.
Considering broad alignment with other emissions reduction programs of similar rigour that provides opportunity for linking in the future.
Considering integration with other provincial environmental policies.

The paper indicates that Ontario’s program would initially limit GHG emissions from fossil fuel-fired electricity generators and large GHG emitters in certain industries, including petroleum refining, chemicals, steel, cement and pulp and paper. The paper also indicates that the program would limit emissions from facilities in these sectors (other than the electricity generation sector) to the level of their current total emissions, with the limit declining thereafter by 5% over five years. Although it does not explicitly advocate a cap-and-trade system, the paper does suggest that the MOE will consider the use of emissions trading mechanisms to establish a carbon price and provide businesses with options on how to achieve reductions at the lowest cost.

In addition, the paper proposes that Ontario’s program would be in place one year prior to federal regulation of greenhouse gases from industry. A one year window will provide time for the province to negotiate and finalize an equivalency agreement with the federal government to ensure there is a single regulator for greenhouse gas emissions in the province.

Ontario acknowledges that other North American jurisdictions are also taking action to address emissions of GHGs. It notes that Quebec, British Columbia, Alberta, Saskatchewan and Nova Scotia all have or are developing regulations to reduce greenhouse gases. It also notes that in the USA, the Regional Greenhouse Gas Initiative limits emissions from electricity generation in north-eastern states, while California has introduced a broad greenhouse gas emissions trading regime with an intention of linking to Quebec’s program.

The MOE will accept submissions on the discussion paper until April 21, 2013. For further information, please refer to the Environmental Registry: Here

California to hold First Auction of GHG Emission Allowances on November 14, 2012

Bill AB 32 requires California to reduce greenhouse gas emissions to 1990 levels by 2020. The cap and trade regulation (“Regulation”) is a key element of California’s climate plan. The Regulation is designed to provide regulated entities with the flexibility to seek out and implement the lowest cost options to reduce emissions. California’s cap and trade program will be second in size only to the European Union’s Emissions Trading System based on the amount of emissions covered. In addition to driving emission cuts in the ninth largest economy in the world, California’s program will provide critical experience in how an economy-wide cap and- trade system can function in the United States.

It is anticipated that California’s emissions trading system will reduce greenhouse gas emissions from regulated entities by more than 16% between 2013 and 2020. Starting on January 1, 2013, the Regulation will apply to large electric power plants and large industrial plants. In 2015, it will extend to fuel distributors (including distributors of heating and transportation fuels). At that stage, the program will encompass around 360 businesses throughout California and nearly 85% of the state’s total greenhouse gas emissions.

Under a cap and trade system, companies must hold enough emission allowances to cover their emissions, and are free to buy and sell allowances on the open market. As part of the cap and trade program, the California Air Resources Board (ARB) will hold allowance auctions to allow market participants to acquire allowances directly from ARB. ARB will conduct the first auction on November 14, 2012 from 10am to 1pm PST. ARB will also conduct the first quarterly reserve sale on March 8, 2013. Auction participants will have to apply to participate in an auction, or submit a bid for reserve sales, and meet financial regulatory requirements in order to participate in an auction or reserve sale.

The November 14^th auction will mark the beginning of the first greenhouse gas cap and trade program in the United States since the Regional Greenhouse Gas Initiative (RGGI), a cap and trade program for power plants in nine northeastern US states, held its first auction in 2008.

California covered entities, opt-in covered entities, and voluntarily associated entities are eligible to participate in the November 2012 GHG allowance auction. Approved offset registries, verification bodies, and offset verifiers are not eligible to participate in auctions as they are not allowed to hold compliance instruments under the Regulation. Prior to participating in an auction, the Primary Account Representative (PAR) and Alternate Account Representative (AAR) that will be authorized to bid on behalf of entities eligible to participate in the auction must be approved users in the Compliance Instrument Tracking System Service (CITSS) and the entity must have an entity account in the CITSS.

The detailed auction requirements and instructions are available online

EC Launches Sustainable Urban Mobility Campaign to Fight Congestion and Pollution

The European Commission (EC) has launched its Sustainable Urban Mobility campaign, which represents a three-year initiative designed to support sustainable urban mobility campaigners in 31 countries. The central objective of the Sustainable Urban Mobility campaign is to promote the advantages of combining different modes of transportation, so its slogan invites people to “Do the Right Mix”. Activities began with the opening of a registration system to support outstanding actions that foster positive change in attitudes and behaviour. This campaign is linked to the European Mobility Week, which runs from September 16 to 22 every year and culminates in the “In Town Without My Car!” day.

A fund of EUR 500,000 is available to support actions demonstrating significant networking and multiplication effects at the local, regional and/or national, or even EU level. Individuals, non-commercial entities (schools, NGOs, public administrations, etc.) and commercial entities are eligible to apply for up to EUR 7,000 in financial support from the EC by participating in the campaign. Applicants may register their actions promoting sustainable urban mobility at http://www.dotherightmix.eu.

In addition, the campaign includes initiatives such as an award for European cities based on their sustainable urban mobility plans, coordinated awareness-raising activities and events in 31 participating countries: EU Member States, EEA Member States (Iceland, Liechtenstein and Norway) and Croatia. The campaign is managed by the Directorate-General for Mobility and Transport and funded through the Intelligent Energy Europe Programme – the EU’s support programme for non-technological actions in the field of energy efficiency and renewable energy sources.

BC Announces New Funding for Public Sector Carbon Neutral Commitments

On April 5, 2011, Environment Minister Terry Lake announced a new $5 million capital program that will be available to school districts for energy-efficiency projects to lower their carbon emissions. The provincial government indicated that this funding reaffirms its commitment to being the first carbon-neutral government in North America.

Starting in 2012/13, the new K-12 energy-efficiency capital program will be available to boards of education through the Ministry of Education. The amount of available funding has been set to be equal to or greater than the total paid by school boards each year for purchases of carbon offsets from the Pacific Carbon Trust (PCT).

In addition to the new funding, the following program enhancements for all public sector organizations were announced:

SMARTTool administration costs will no longer be charged to public sector organizations, resulting in $850,000 of cost savings that will be absorbed by the PCT.
To ensure the PCT’s offset portfolio meets the needs of stakeholders, the PCT will create an advisory panel. The panel will play an ongoing role in reviewing the structure and diversity of the carbon offset portfolio and provide suggestions regarding future offset opportunities. The panel will include representatives from the private and public sectors that purchase offsets from PCT, as well as select carbon-industry experts.
To streamline the current system, a link will be established that will feed energy data directly into the SMARTTool to reduce administrative costs associated with measuring emissions.

Under BC’s Carbon Neutral Regulation of the Greenhouse Gas Reduction Targets Act, certain public sector organizations were required to be carbon neutral by 2010. In June 2011, it was announced that BC had become the first major jurisdiction in North America to achieve carbon neutral operations as of 2010. This means that BC’s public sector including schools, post-secondary institutions, government offices, Crown corporations and hospitals have all achieved net-zero greenhouse gas emissions.

California to Appeal Superior Court Decision to Halt Carbon Market

On May 20, 2011, San Francisco Superior Court judge Ernest Goldsmith issued a decision requiring the California Air Resources Board (CARB) to halt action on implementing its planned emissions cap-and-trade program until it has explored alternatives to meet California’s emission reduction targets. The decision follows a ruling delivered in March 2011 in which the judge said CARB had violated the California Environmental Quality Act by failing to adequately assess alternative emission reduction mechanisms, such as a carbon tax. The ruling is the result of legal action brought by the Association for Irritated Residents and other environmental justice groups, which argued that the proposed cap-and-trade program could damage air quality in some parts of the state.

The cap-and-trade program is part of AB 32 (Global Warming Solutions Act), California’s landmark climate change law, which is designed to lower California’s greenhouse gas emissions to 1990 levels by 2020. AB 32 also includes increased fuel efficiency standards and a renewable electricity target of 33% by 2020. Under the ruling, CARB must set aside its December 2010 decision approving the trading system for emitters over 25,000 metric tons per year, and must cease all rule-making and implementation activities related to cap-and-trade until it complies with the law. In particular, the judge said that CARB must go back and show why it made the decision to implement cap-and- trade. The trading program is designed to cover 85 percent of the state’s industrial emissions by 2020 and would include emissions from power plants, oil and gas refineries, transportation fuels and other heavy industries.

On May 23^rd, California’s top attorney initiated an appeal of Judge Goldsmith’s decision. Depending on the length of the appeal process, the cap-and-trade program could be delayed, perhaps until 2013. In the meantime, California can continue with its renewable energy targets, low-carbon fuel standard and energy efficiency measures, all of which are unaffected by the judge’s ruling.

Another Study links High GHG Emissions with Negative Impact on Company’s Value

A study by researchers at the University of Wisconsin-Madison, Georgetown University and the University of Notre Dame has found that high levels of greenhouse gas (GHG) emissions can have a negative impact on a company’s value. According to the study – Voluntary Disclosures and the Firm-Value Effects of Carbon Emissions (April 2011) – a company’s value decreases on average by $202,000 for every additional thousand metric tons of emissions it produces.

Researchers used hand-collected carbon emissions data for 2006-2008 that Standard and Poor’s (S&P) 500 companies disclosed voluntarily to the Carbon Disclosure Project to examine two issues: (1) firm-level characteristics associated with the choice to disclose carbon emissions, and (2) relationship between carbon emission levels and firm value. With respect to the first issue, researchers found a higher likelihood of carbon emission disclosures by firms with superior environmental performance, conditional on firms taking environmentally proactive actions. However, researchers found no association between inferior environmental performance and the likelihood of disclosing carbon emissions, conditional on firms taking environmentally damaging actions. Furthermore, researchers found that companies are more likely to voluntarily disclose their carbon emissions as the proportion of industry peer firm disclosers increases. In connection with the second issue, the researchers found a negative association between carbon emission levels and firm value. From its sample of S&P 500 companies, the study found that a company’s value decreases on average by $202,000 for every additional thousand metric tons of GHG emissions it produces.

In the study, researchers also pointed out that according to the 2009 Goldman Sachs’ GS Sustain Report it is expected that the relationship between carbon emissions and global climate change will drive a redistribution of value from firms that do not control their carbon emissions successfully to firms that do.
The study may be accessed online

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.