Planning for 2010

Planning for 2010

Monitoring and Evaluation
On my blog (www.ccesworld.com/blog) I have posted discussions about how a climate change program can be a financial boon for companies. My most recent one focused on a more satisfied workforce. While that’s nice by itself, this has a financial benefit attached to it. A more satisfied workforce has been shown to result in lower turnover and tremendous savings in lost production, time spent finding replacements, and training.
And now the big elephant has entered the room: in the US soon you’ll HAVE to address GHG emissions. There is now a federal GHG emission estimation and reporting bill (summarized in detail in an earlier Environmental News for You). I hope that those subject to the rule (in about 35 industries or any facility emitting at least 25,000 metric tons of CO2 equivalents) are working hard to prepare as data collection for reporting begins on January 1 (CCES can help!). The federal government will promulgate a GHG emission reduction (“cap and trade”) rule. Regardless of how one feels about climate change, all signs point to such a bill passing in 2010. Unlike what’s going on now with health care legislation, there are believed to be enough Republicans in favor of such a GHG reduction bill that a filibuster-proof majority can be reached (subject to negotiation). Thus, it is likely that GHG emission reduction rules will be promulgated in 2010 to go into effect likely in 2011.
Besides compliance, such legislation will have a financial angle, as reducing GHG emissions will have a price attached to it. In other words, your company, if subject to the bill, will have an opportunity to make or lose money. Therefore, the stakes are high; not just in compliance, but financial liabilities and opportunities, as well. It is in your best interests to devote resources to prepare now – even before a bill is promulgated.
A typical attitude is to wait until a proposed rule becomes law and then study and address it. For the US GHG regulation, this is risky, as compliance will involve complex business and technical approaches.
There are many things that you can do now to prepare for climate change legislation that will have to be performed no matter what the final form of the bill. Here’s a discussion of just a few.
1. Perform a baseline GHG emissions inventory (carbon footprint). No matter what form the final federal rule will be, affected companies will be required to determine baseline GHG emissions to determine eventual reductions. A thorough, complete inventory of all processes and equipment under your control and a determination of historic GHG emissions (preferably over several prior years) are necessary. It is important to fully understand all potential sources of GHG emissions, including those considered indirect, at all facilities, including office buildings and warehouses. A critical issue with such inventories is data quality. The federal rule will undoubtedly have guidelines to ensure a minimum data quality. Make sure that data you collect (i.e., fuel usage, electricity usage, etc.) is complete, accurate, and reproducible. And keep records. Speaking of which…
2. Develop a system to track and manage data and GHG emissions. The amount of data to be collected and managed can be overwhelming, based on operational complexity. It is critical to invest in a system to manage such data, perform calculations, store emissions data, and produce different report types. GHG emission software already exists for many applications. Even without such software, a system can be created to ideally integrate with your existing environmental and business software systems.
3. Assess the areas where GHG emission reduction makes the most sense. Once a satisfactory inventory is completed, evaluate it to determine GHG emission reduction opportunities. Which processes and activities produce the most GHG emissions? Evaluate technically, then prioritize. Then …
4. Actually reduce GHG emissions in some places. Select a project or two to implement. Were they successful and cost-effective? Now is the time to do it, rather than when under time pressure. Some worry they may be “punished” for such emission reductions (a reduced baseline). That’s not likely to be the case as the USEPA has stated that any final bill will contain “early action rewards” for companies who have reduced their GHG emissions early and posted these in a known registry. Testing reduction strategies early plus making adjustments later makes implementing strategies very cost effective.
The bottom line: It is in your company’s interest to prepare for the upcoming federal GHG emission reduction rule in 2010 even if its exact final language and timing are unknown. Your company will need to prepare a baseline GHG emission inventory, so it is useful to do one soon. Assessing the inventory meaning and emission reduction opportunities early will benefit your company in the long term, particularly with the financial and environmental considerations. 2010 is the time to seriously prepare your GHG emission program.
Wishing all my readers a safe and meaningful holiday season, and a happy, healthy, productive 2010!
Read more useful material in the blog: www.CCESworld.com/blog
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This document is not intended to be a complete how-to on preparing for the future federal GHG emission reduction rule. All entities should work with experienced technical, legal and financial professionals when preparing for any new rules. CCES has the experience in helping large and small firms prepare for the regulation, including performing baseline GHG emission inventories and the strategizing, management, and successful implementation of GHG emission reduction projects discussed above. CCES can help you maximize other financial gains, such as energy cost savings, and can also help you develop a cost-effective GHG data management program. Let us help you develop from scratch or grow effectively your climate change program, so you can comfortably comply with future federal rules and gain maximum financial benefits.