Comments on Draft Technical Guidelines for the Voluntary Reporting of Greenhouse Gases (1605(b)) Program

Comments by The Pew Center on Global Climate Change  Regarding Draft Technical 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 “Draft Technical Guidelines for the Voluntary Reporting of Greenhouse Gases (1605(b)) Program” (70 Fed. Reg. 15164 (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)). These comments on the Draft Technical Guidelines follow an additional response [1] to the “Interim Final, General Guidelines for the Voluntary Reporting of Greenhouse Gases (1605(b)) Program [2]” (70 Fed. Reg. 15169 (March 24, 2005)), submitted separately.

We appreciate the attempt that has been made to develop a comprehensive program for greenhouse gas reporting. The use of a ratings system is a promising approach for addressing the wide range of GHG emission situations facing industries and sectors that a reporting system should cover. However, the values established for the various methodologies may result in inequities between registered reductions and may unintentionally disadvantage some industries or entire sectors. Likewise, other decisions have been made about which entity has the right to register particular emission reductions both within and across sectors. Where the range of stakeholders can reach agreement on equitable arrangements for allocation and reporting of emissions reductions, we recommend DOE consider adopting these arrangements. The Pew Center recommends that the first reporting period be considered a trial to determine how well the guidelines support sufficient and equitable participation in the registration of real reductions.

Following the first period, these Guidelines should be re-evaluated based on reporters’ experiences with (and the extent of participation in) the program in all sectors and revised in the light of these experiences. Finally, existing discrepancies between the General Guidelines and the Technical Guidelines (for example, discrepancies in accounting methods specified for geological sequestration) should be resolved prior to the Guidelines becoming final.