Guidelines for Voluntary Reporting of Greenhouse Gas Emissions and Reductions, and Carbon Sequestration

DEPARTMENT OF ENERGY

Office of Policy

Guidelines for Voluntary Reporting of Greenhouse Gas Emissions

and Reductions, and Carbon Sequestration

AGENCY: Department of Energy (DOE).

ACTION: Notice of availability of guidelines.

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SUMMARY: Pursuant to Section 1605(b) of the Energy Policy Act of 1992,

the Department of Energy has developed guidelines for the voluntary

reporting of greenhouse gas emissions, their reduction, and carbon

fixation achieved through any measure. The data will be reported on

forms to be developed by the Energy Information Agency (EIA) and

entered into an EIA database.

The guidelines provide for the voluntary reporting of greenhouse

gas emissions and reductions, and of carbon sequestration. The

guidelines and supporting materials will assist parties in analyzing

activities and determining emissions and reductions in order to

voluntarily report this data. The EIA reporting forms will be

consistent with the guidelines. The guidelines and supporting material

are finalized and will be available for distribution on or before

October 31, 1994.

DATES: The Guidelines for the Voluntary Reporting of Greenhouse Gases

under Section 1605(b) of the Energy Policy Act of 1992 will be

available for distribution on or before October 31, 1994.

ADDRESSES: Copies of the guidelines and supporting documents are

available in hard copy or on 3\1/2\'' diskette. Copies may be obtained

by telephone request to (202) 586-3660, by facsimile request to (202)

586-2062 or (202) 586-3047, or by writing to the Office of Global

Environment (PO-63), U.S. Department of Energy, 1000 Independence Ave.,

SW., Washington, DC 20585. Please request publication DOE/PO-0028, and

indicate hard copy or diskette version.

A docket (Docket PO-VR-94-101) containing information related to

development of the guidelines and a copy of the guidelines and

supporting documents is available for public inspection in the DOE

Freedom of Information Reading Room, Room 1E-090, at the address listed

above, between the hours of 9 a.m. and 4 p.m. Monday through Friday.

FOR FURTHER INFORMATION CONTACT: Jean Vernet, Office of Global

Environment (PO-63), U.S. Department of Energy, 1000 Independence Ave.,

SW., Washington, DC 20585, phone (202) 586-4755; or Elmer Holt, Office

of Global Environment (PO-63), at the same address, phone (202) 586-

0714.

SUPPLEMENTARY INFORMATION:

I. Statutory Authority and Background

II. Discussion of Final Guidelines and Comments Received

A. Organization of the Final Guidelines and Supporting Materials

B. Purpose of the Guidelines and Design Principles

C. Changes to Draft Guidelines for Final Guidelines

1. Gases covered

2. Limitation on Vintage of Reportable Projects

3. Direct and Indirect Emissions

4. Primary and Secondary Effects

5. Amending a Previous Year's Report

6. Radiative Forcing of Greenhouse Gases

D. Changes to Draft Sector-Specific Supporting Documents for Final

Sector-Specific Supporting Documents

1. Electricity Supply

2. Residential and Commercial Buildings

3. Industrial

4. Transportation

5. Forestry

6. Agricultural

7. Adjusted Electricity Emissions Factors by State

III. Administrative Requirements

I. Statutory Authority and Background

Under Section 1605(b) of the Energy Policy Act of 1992 (EPAct; Pub.

L. 102-486), the Secretary of Energy with the Energy Information

Administration, and in consultation with the Environmental Protection

Agency (EPA), is required to establish a voluntary reporting system and

database on emissions of greenhouse gases (GHGs), reductions of these

gases, and carbon fixation. DOE is required to publish, after public

comment, guidelines setting procedures for the accurate voluntary

reporting of information on: (1) Greenhouse gas emissions on an annual

basis for the baseline period 1987 through 1990, and for subsequent

calendar years; (2) annual reductions of greenhouse gases and carbon

fixation achieved through any measure; and (3) reductions in greenhouse

gas emissions achieved voluntarily, or as a result of plant or facility

closings, or as a result of State or Federal requirements.

The guidelines and supporting materials finalized today will assist

those who wish to participate in determining or developing information

capable of being reported. The reporting forms and database system

required under Section 1605(b) are to be developed by EIA and must be

consistent with the guidelines.

Draft guidelines and supporting materials were made available for

public comment on June 1, 1994 (59 FR 28345); that notice discusses the

draft guidelines. A public hearing on the draft guidelines was held on

June 29, 1994. The draft supporting document for the agricultural

sector was made available June 30, 1994 (59 FR 33733). Comments were

provided by individuals and associations representing: public interest

environmental and land use groups; investor-owned and publicly-owned

utilities; independent power producers; oil production and use; coal

production and use; motor vehicle manufacturing and use; chemical

manufacturing; and academic, commercial, and public interest forestry

interests.

II. Discussion of Final Guidelines and Comments Received

A. Organization of the Final Guidelines and Supporting Materials

In response to comments, the final guidelines and supporting

materials have been re-organized from that presented in the draft. The

coverage of each sector-specific supporting Part, however, is the same

as that contained in the parallel Part of the draft documents. The

final guidelines and supporting documents, DOE/PO-0028, are organized

in three volumes:

Volume 1--General Guidelines

Volume 2--Sector-Specific Issues and Reporting Methodologies Supporting

the General Guidelines

Part 1--Electricity Supply Sector

Part 2--Residential and Commercial Buildings Sector

Part 3--Industrial Sector

Volume 3--Sector-Specific Issues and Reporting Methodologies Supporting

the General Guidelines

Part 4--Transportation Sector

Part 5--Forestry Sector

Part 6--Agricultural Sector

The material provided in the draft supporting document, Part 7,

dealing with Global Warming Potentials, has been revised as discussed

below, and now appears as Appendix E to each supporting volume.

B. Purpose of the Guidelines and Design Principles

The final guidelines and supporting materials have been developed

to reflect the goal of maximizing participation without compromising

the usefulness of the data voluntarily submitted. Commenters on the

draft guidelines generally supported the appropriateness of this goal,

although some did not agree on how to strike a balance between

maximizing participation and establishing a meaningful data reporting

system. The flexibility provided by the draft guidelines, which takes

into account the reporter's ability to use existing information and

select appropriate quantification methods, was supported by many

commenters as necessary to encourage participation.

However, some comments from environmental public interest groups

and forestry public interest groups urged that the final guidelines

include requirements for verification of emissions reductions and

carbon sequestration data. These commenters believe that the

flexibility provided by the program made data verification essential to

the credibility of the information entered into the database. Many of

these comments acknowledged that the statute directed neither DOE nor

reporters to obtain verification of data reported, but suggested that

third party verification could provide users of the database with

better assurances of its accuracy.

Some of these commenters indicated that, in the alternative, the

program should direct reporters to indicate the basis for the data

submitted based on a categorization system, and that the database

should be designed to allow sorting of data on the basis of this

categorization. For example, a report would indicate that data was

based on measurement, estimation, or use of default tables, and whether

emissions reductions project reports were accompanied by historic or

entity-wide emissions data. A database user would be able to retrieve

reported data on the basis of these categories.

In order to provide the flexibility necessary to encourage

reporting, the guidelines do not provide prescriptive features such as

verification. Rather, the guidelines indicate that a reporter will be

asked to categorize the data submitted. This categorization will

include third party verification as well as whether the data was

measured or estimated. Segregation of data by categories will be

possible.

DOE believes the approach of requesting the identification of data

derivation, and of any data verification performed, accommodates both

the need to maximize participation by providing flexibility, and the

need to create a useful and accessible database.

C. Changes to Draft Guidelines for Final Guidelines

After reviewing the comments received, DOE revised several

provisions of the draft general guidelines and some provisions of the

sector-specific supporting documents. The changes to the draft

guidelines include: the addition of gases to the list of those

reportable under the program, with delayed implementation for some of

those gases not covered in the draft guidelines; a limitation on

reporting project activities to those that achieved new emission

reductions or carbon sequestration beginning with January 1, 1991;

revision of the discussions about distinctions between primary and

secondary effects, and between direct and indirect emissions; and

guidance on amending a previous year's report.

A discussion of responses to significant comments on issues in the

draft general guidelines appears below. Significant changes as a result

of comments received on the sector-specific documents are discussed

below by sector document.

1. Gases Covered

The legislation does not define ``greenhouse gases.'' The draft

guidelines covered emissions of carbon dioxide, methane, nitrous oxide,

as well as many of the halogenated substances. The final guidelines add

two halogenated substances, halon 1211 and halon 2402, to the list of

gases and substances covered. In addition, DOE announces the delayed

addition of three greenhouse gases, nitrogen oxides, nonmethane

hydrocarbons, and carbon monoxide, to the reporting program starting

with the third reporting cycle of the program which is expected in

1997.

a. Additional Gases to be Covered--Conventional Pollutants

Comments on the gases and substances covered by the draft

guidelines supported expansion of the program to a more comprehensive

list of greenhouse gases, especially some conventional, or

``criteria,'' pollutants regulated under the Clean Air Act for which

emissions data is collected by EPA and State agencies under various air

quality programs. These gases are nitrogen oxides, nonmethane

hydrocarbons, and carbon monoxide. Although these gases are not direct

greenhouse gases, they contribute to the formation of carbon dioxide

and/or tropospheric ozone.

The international scientific community has been unable to quantify

the differential radiative activity of these gases, and thus has not

provided an index of the climate change effects of these gases relative

to carbon dioxide. Because emissions data reported under the program

will be reported in units of weight, and not reduced by any common

index of comparative radiative effects, it is unnecessary to exclude

gases from the program solely on the basis that a quantification of

comparative effects is not available.

DOE agrees that a more comprehensive 1605(b) reporting program

should cover these indirect gases, and has expanded the gases covered

by the voluntary reporting program to include nitrogen oxides,

nonmethane hydrocarbons, and carbon monoxide. However, for the reasons

discussed below, DOE is delaying the programmatic acceptance of

voluntarily reported data on emissions and emissions reductions of

these gases for a period of two years. Thus, reports of data related to

these gases will first be accepted by EIA during the third reporting

cycle of the program, i.e. with reports filed in 1997. These reports

may include the results of activities beginning January 1, 1991, as

well as historic emissions data on these gases for the period 1987 to

1990.

The primary reason for delaying the addition of these gases is to

aid in the efficient administration of this new program. Neither DOE

nor EIA has sufficient experience in voluntary reporting to predict the

volume of participation in this program or the difficulties that may

arise in its implementation. EIA expects that experience gained in the

first two years of the program will enhance its ability to smoothly

accommodate this expansion of the reporting program.

b. Additional Gases to be Covered--Halogenated Substances

Comments were also received on the list of halogenated substances

for which emissions and reductions will be reportable. In response to

these comments, the final guidelines add two halogenated substances,

halon 1211 and halon 2402, to the list of reportable gases. Given the

limited amount of reporting anticipated on these substances, initial

coverage of the program includes these gases.

As explained in the June 1994 notice of availability for the draft

guidelines, the inclusion of some halogenated substances in the

voluntary reporting program is based on the language of Section

1605(b)(1)(B), referring to the reportability of reductions in

greenhouse gas emissions achieved through ``chlorofluorocarbon capture

and replacement.'' Without this language, DOE might have limited the

voluntary reporting program to those gases covered by the United

Nations Framework Convention on Climate Change, thus excluding the

chlorofluorocarbons (CFCs) and other halogenated substances, including

the two halons now covered, from the reporting program.

One comment noted that the draft guidelines' failure to list halon

1211 and halon 2402 as reportable gases was inconsistent with the

listing of halon 1301. The draft guidelines and supporting materials

listed only those halogenated substances for which the

Intergovernmental Panel on Climate Change (IPCC) had published an index

of global warming potential (GWP) relative to carbon dioxide. While

there are internationally accepted indices of stratospheric ozone

depletion potential for halogenated and bromide substances in addition

to those listed in the draft guidelines and supporting documents, the

IPCC published a GWP for halon 1301, but not for any other halon.

Based on stratospheric ozone depletion characteristics, the

halogenated substances are covered by an international agreement, the

Montreal Protocol on Substances Depleting the Stratospheric Ozone, and

under U.S. law are regulated under Title VI of the Clean Air Act

Amendments of 1990. These gases are greenhouse gases, although they

also have the antagonistic characteristic of destroying tropospheric

ozone, which tends to indirectly produce global cooling. These

antagonistic effects complicate the analysis of their impact on the

global climate, and have divided the scientific community over whether

the net effect of some of these gases will be global warming or

cooling.

This division in the scientific community has made it difficult to

determine the quantitative global warming potential of these gases.

Because emissions data reported under the program will be reported in

units of weight, and not reduced to a standard measure by application

of a common index of comparative radiative effects, and to be

consistent with the decision discussed above on conventional

pollutants, halon 1211 and halon 2401 are added to the list of gases

for which emissions may be reported under the program. Based on the

limited amount of activity in production and use of these substances,

and on the similarity in emissions of these substances to other

halogenated substances, DOE has determined that there is no

administrative need to delay acceptance of submissions on these gases.

2. Limitation on Vintage of Reportable Projects

The General Guidelines include a new section, discussing the

limitation on reporting projects which resulted in a reduction in

emissions, but on which activity commenced before 1991. The final

guidelines permit reporting as projects only new (post-1990) emissions

reductions and carbon sequestration. Pre-1991 emissions reductions will

be reflected in emissions reporting only. Thus, the results of all

emission reduction activities which are first achieved in 1991 are

reportable as projects, even if the activity commenced before 1991. For

example, in the case of an ongoing demand side management program,

emissions changes arising from energy savings through appliance

replacement in 1991 can be reported as project results, but the effects

of appliance replacements before 1991 are not reportable as emissions

reduction projects. Rather, these effects are subsumed in emissions

reporting for the baseline period of 1987 through 1990.

The draft guidelines had no comparable discussion. Some commenters

maintained that a time limitation on reportable emissions reduction

projects was necessary, particularly because under the guidelines

reporters may separately report emissions and emissions reductions.

These comments indicated that the statutory language of section

1605(b)(1)(A)(i) providing for 1987 through 1990 as baseline years for

emissions reporting implied that emissions reductions reporting under

section 1605(b)(1)(B) was limited to reductions occurring after 1990.

Reductions occurring before 1991 would be reportable only for their

effect on emissions reported for the baseline years, rather than

separately as emissions reductions projects.

Since the statutory language on reporting emissions reductions is

not explicitly tied to any specific year or years, and the years 1987

through 1990 are referred to as the baseline period, DOE is persuaded

that goals of the reporting program are best served by limiting reports

of emission reduction projects to new emissions reductions after 1990.

Many emission reduction projects have multi-year or multi-decade lives;

without a time limitation, the database would include the emissions

reductions results of older activities more appropriately reflected

within emissions reporting rather than highlighted separately as

emissions reduction projects.

3. Direct and Indirect Emissions

The reporting program covers activities which directly or

indirectly result in greenhouse gas emissions or emissions reductions.

DOE has revised the text of the General Guidelines to clarify the

distinction between direct and indirect emissions in order to assist

reporters in identifying the distinction.

Some commenters supported limiting the program to submissions of

data on direct emissions, and to activities that directly produce or

reduce emissions, in order to provide clarity in the program's

database. Other comments supported the draft's inclusion of activities

that indirectly impact greenhouse gas emissions, based on the statutory

listing in Section 1605(b)(1)(B) of activities which indirectly affect,

or may indirectly affect, emissions or reductions. Additionally, many

comments evidenced confusion over the draft's discussion of direct and

indirect emissions.

DOE agrees that the statutory listing of activities which

indirectly affect emissions, as well as activities that directly affect

emissions, supports the inclusion of both direct and indirect emissions

in the reporting program. DOE also agrees that these concepts are

potentially confusing. To assist reporters in identifying direct and

indirect emissions, DOE has revised the text of the General Guidelines.

It is apparent from many of the comments that this confusion was

largely created by intertwining the concepts of primary and secondary

effects of an activity with the concepts of resulting direct and

indirect emissions.

In response, DOE has eliminated the distinction between primary and

secondary effects of a project, leaving a single concept of

``effects''.

4. Primary and Secondary Effects

Based on comments expressing confusion over the concepts and the

draft guidance for the inclusion of both primary and secondary effects

in project analysis, the final guidelines have eliminated the

distinction. While the concepts are still presented in Section GG-5.9,

the reporter is urged to consider and report the known and quantifiable

``effects'' of a project without regard to whether they are primary or

secondary. To provide additional clarity, the final guidelines also

present examples of different types of effects.

5. Amending a Previous Year's Report

The final guidelines add a provision which allows reporters to

amend any previous year's report. The program will, for example, accept

reports based on estimated and default data, which will be identified

as such by the reporter. (See discussion at II.B., above.) Where a

reporter subsequently develops better data, for example through field

measurements or utility-specific emissions factors, the original report

may be modified based on information developed using the later-acquired

data. The amended report will include the reason for the revision and a

comparison of the amended report's changes to the original report.

The primary reason for adding this provision is to encourage

reporters to develop their own activity-specific data, without

discouraging reporting based on less-specific estimation or default

data.

6. Radiative Forcing of Greenhouse Gases

The language of Section 1605(b)(1) provides that the reporting

guidelines are ``to establish procedures for taking into account the

differential radiative activity and atmospheric lifetimes of each

greenhouse gas.'' The draft guidelines and the supporting materials

included as Part 7, ``Global Warming Potentials'' (GWPs), describing

the GWP index developed by the IPCC as a simple method for representing

the relative effects on climate resulting from a unit mass of a

greenhouse gas.

Comments unanimously supported DOE's decision to require that

emissions data be reported only in units of greenhouse gases emitted,

and not to require reporters to convert these data to the effects of

the gases reported relative to carbon dioxide. The final guidelines

continue to direct that reported data will be in units of gas emitted.

Commenters expressed concerns that (1) the concept of GWPs was too

complex to be useful to most reporters in developing GHG mitigation

options; (2) the discussion in draft Part 7 of the scientific basis of

GWPs was flawed; and (3) use of scientific work not yet formally

adopted by the IPCC was inappropriate.

In response to comments, draft Part 7 has been substantially

condensed and appears as Appendix E in the two supporting volumes. The

expansion of draft Part 7 to clarify fully the many complex and

evolving scientific issues was deemed outside the scope of the

voluntary reporting program. A brief discussion of the concept,

together with a chart of the latest quantitative GWP index developed by

the international scientific community, is provided in the Appendix.

The reader/user is referred to other sources for additional

information.

DOE agrees that the scientific concepts involved in GWPs, such as

time horizons, carbon cycle models, and integration time scales, may

not be clearly understood by many in the general reporting population.

The ongoing improvements in our understanding of the complex global

climate system and analytic models developed are evidenced, as

discussed in the Notice of Inquiry preceding the draft guidelines, by

the 1992 revision of the 1990 IPCC report on GWPs. Further, revisions

to the 1992 report have been approved by an IPCC subsidiary body,

Working Group I, and will be published later this year. It is from this

anticipated publication that the GWPs provided in the draft and final

guidelines are taken.

The IPCC, an international body charged with reaching international

consensus on the complex scientific matters in climate change, is

supported by the United States. IPCC work will ultimately be a factor

in both domestic and international analyses on climate change

mitigation options. It would thus be imprudent for the DOE reporting

guidelines to address differential radiative forcing in a manner

inconsistent with the IPCC. The 1994 revisions to the IPCC GWP index

have been approved by Working Group I and are expected to be formally

accepted by the full IPCC soon after publication of the final

guidelines. DOE is using this material in advance of its formal

acceptance for administrative ease.

7. Editorial and Minor Revisions

In response to various comments, editorial revisions were made

throughout the General Guidelines and the supporting documents as

follows.

Case studies and examples. Case studies and examples are provided

for the purpose of illustrating the process of project analysis in

light of a reporter's purpose and sector-specific circumstances and

conditions. Some commenters suggested that some of the case studies and

examples provided were unrealistic, that they suggest a greater

reporting burden for reporters in some sectors than in others, or that

they appear to require the use of certain approaches and methods for

some activities.

To address these comments, the following text has been added to all

case study and example presentations:

Note: This example illustrates only one approach in analyzing a

project; your analysis, methods, and calculations will vary depending

on your particular circumstances, the geographic location of the

project, and other factors.

Examples are intended to provide, in an educational manner,

illustrations of various approaches to project and emissions analysis

permitted within the guidelines. They are not intended to imply any

additional directions or restrictions on reporting over and above that

provided by the Guidelines. The case studies and examples do, however,

suggest to potential reporters different ways in which existing data

and resources may be used to develop a report. The illustrated cases

thus differ in detail based on the stated purpose of the hypothetical

reporter for reporting, and the individual circumstances surrounding

the project and the reporter. Consistent with the goal of maximum

participation in the program, the flexibility of the reporting program

is not bound by any particular case study or example discussion on any

issue.

Subjective Terminology

Comments were made that the use in the guidelines and the

supporting materials of certain descriptive terms, relative to a

reporter's decisions regarding the data developed and reported, were

inappropriate within a voluntary program. The program's flexibility

allows reporters to select among various approaches in developing a

report. These selections do not encompass comparative value of the

reporter's activities. No value judgments are intended by the use of

subjective terms in any description of the reporter's choice of

approaches. Accordingly, the final guidelines and supporting materials

have been revised to minimize use of these terms, and to better reflect

that judgments on the quality of the data reported are to be made by

the reporter and database user, and not by the reporting program. Where

these terms remain in the guidelines and supporting documents, they are

intended to reflect differing perspectives of both reporters and

database users on choices permitted by the reporting program.

D. Changes to Draft Sector-Specific Supporting Documents for Final

Sector-Specific Documents

Comments were received on all draft sector specific supporting

documents. Revisions to the draft guidelines in response to comments on

less significant technical, mathematical, or editorial errors in the

draft sector specific supporting documents are not individually

discussed in this notice, but were considered and addressed where

appropriate.

Most comments fall into several categories of issues, including

those that have been addressed in the final General Guidelines and

discussed above in section II.C. of this notice. These categories

include: failure to discuss all emissions reduction or carbon

sequestration activities applicable to the sector; criticism of the

case studies' use of unrealistic circumstances; the accuracy,

completeness, and degree of conservativeness of default tables; and the

lack of balance among sector documents indicating differing reporting

burdens.

The program is expressly intended to provide reporters with the

flexibility to report on the achievements of all emissions reduction

and carbon sequestration activities. The failure of the draft

guidelines and supporting materials to discuss or list any particular

activity does not indicate that its achievements are not reportable

under the 1605(b) program.

In response to comments, the final supporting documents add

discussions of some additional emissions reduction and carbon

sequestration approaches, and provide more emphasis to some of the

approaches discussed in the draft. Nevertheless, the guidelines and

supporting documents are not intended to provide an exclusive list of

all activities that may be reported. The guidelines could not, for

example, provide identification and quantification of achievements from

the novel, innovative actions for which the information sharing

function of the voluntary reporting program is paramount.

As discussed above in C.7., the guidelines and supporting documents

use case studies and examples to illustrate the application of concepts

and varied approaches to project analysis and reporting. Reporters are

not bound by the particulars of any presentation. Rather, the

guidelines provide reporters the flexibility needed to adapt project

analysis approaches to particular circumstances, including the type of

project, the availability of necessary data, and the purpose for

reporting.

Thus, while revisions have been made in many case studies and

examples throughout the documents in response to comments regarding

realism, these study examples are not intended to be exhaustive of the

range of appropriate approaches that reporters may develop and use to

determine the data to report under this program.

Significant comments were received on the accuracy, completeness,

and degree of conservativeness of the default tables provided in the

supporting documents. Based on DOE's technical judgment on individual

comments, errors have been corrected. Responses to these comments on

specific sector default tables appear below in the discussion of the

relevant sector.

In keeping with the flexibility of the program, reporters are

encouraged to use and develop data specific to the project being

reported to accommodate their individual circumstances. The continued

inclusion of default tables is, however, in keeping with the goal of

maximum participation, where the wide disparity among potential

reporting populations supports the need to provide some ``lookup''

tables for use at the discretion of the reporter.

Default tables, by their nature, may provide an easy way for

reporters to estimate the quantity of certain factors they may need in

order to report. By virtue of their ease of use, these tables cannot

accommodate all variables involved; rather, they are based on judgments

on appropriate methodologies and available data. In some fields of

endeavor, there is no apparent consensus on methodologies and the

quality and quantity of data needed either to develop default tables or

to definitively judge their conservativeness. The default tables

provided are, in DOE's judgment, generally conservative.

Some commenters asked that DOE add default tables covering

additional data quantification areas. While DOE agrees that the

addition of tables in these documents could be helpful to reporters,

their development did not warrant a delay in issuing the final

guidelines and supporting documents. In many instances, measurement and

other methodologies are in their relative infancy. DOE expects that

data and methodologies will evolve as national and international

interest continue in the areas of greenhouse gas emissions reduction

and carbon sequestration. Since reporters are permitted to develop

their own data and submit it to the voluntary reporting program, the

program itself may aid in the development of methodologies and the

accumulation of data to advance knowledge in these areas. DOE

acknowledges that sector-specific documents appear to differ greatly in

the detail with which applicable concepts and approaches are discussed.

This distinction was especially noted in comments on the Electricity

Supply Sector, Residential and Commercial Buildings Sector, Industrial

Sector and Forestry Sector documents, expressing concern that the

differences may indicate a higher reporting burden for these sectors.

The differences in focus and depth are based primarily on the

breadth of technical knowledge of each sector's greenhouse gas and

emissions reduction or carbon sequestration features, including the

knowledge held by each sector's population and the degree to which

reporters will have or can develop sufficient data necessary for a

report. These differences in focus and depth do not direct any

additional or supplementary requirements for these sectors. Minimum

reporting requirements, set forth in section GG-6 of the final General

Guidelines, are identical for all reporters and projects, regardless of

sector.

1. Electricity Supply

In addition to the revisions discussed above, in response to

comments on the draft Electricity Supply Sector document, the final

Electricity Supply Sector document includes more prominent mention of:

(1) The possible use of Integrated Resource Planning data and data

development methods; (2) the role of least-cost or other dispatching

modes; (3) the role of hydroelectric power in renewable energy; and (4)

emissions reduction projects in electrotechnologies. The discussion of

relevant electrotechnologies has been augmented in the Industrial and

Transportation Sector documents as well.

Comments were received on requiring reporters in this sector to use

certain existing Federal or State requirements, or other existing

protocols in developing reporting data. One example of a Federal

protocol is the EPA's Conservation and Verification Protocol, 40 CFR

Part 73, which is used in the acid rain program under title IV of the

Clean Air Act Amendments of 1990 to determine the distribution of bonus

sulfur dioxide allowances based on electricity conservation programs.

Another example under the Federal acid rain program is EPA regulations

providing for monitoring or estimating and reporting carbon dioxide

emissions from certain boilers. Many States also have protocols dealing

with estimating energy savings from demand side management (DSM)

programs.

While activities in this sector are characterized by an extensive

array of measurement and estimation methodologies and protocols, many

of which are mentioned in the guidelines and supporting documents, DOE

does not require their use for the reporting program. Consistent with

the flexibility of the program, reporters may choose to use appropriate

protocols and data developed for other reasons, including compliance

with Federal and State requirements.

Significant revisions to some of the examples for this sector were

made in response to comments that the scenarios and quantification

specifics provided were unrealistic. In addition to these revisions,

the language of the caveat discussed in section II.C.7., above, has

been added to the presentation of all examples for the purpose of

indicating that the example is meant to illustrate concepts, not to

prescribe the use of specific approaches.

2. Residential and Commercial Buildings

Comments on the supporting document for the Residential and

Commercial Buildings Sector reflect similar concerns to those raised on

the Electricity Supply Sector document. In response to comments, DOE

has added discussions of electrotechnologies specific to this sector

and identified additional conservation techniques. DOE has clarified

that the ability to report the results of an activity is not dependent

on whether that technology or technique is mentioned in the guidelines

or supporting documents.

Activities in this sector are characterized by an array of

measurement and estimation methodologies, some of which are mentioned

in the document. Comments were received on requiring reporters to use

specific protocols available for this sector. For the same reasons as

discussed in section D.1., above, the guidelines do not prescribe the

use of specific methodologies or protocols for measurement or

estimation.

3. Industrial

In response to comments, DOE has modified discussions on the

appropriate consideration of the obsolescence of equipment in

determining the reference case for reportable projects. Biomass

emissions factors have been clarified, and the distinction between

temporary and permanent fuel switching has been eliminated.

Similar to other sector-specific documents, the final Industrial

Sector supporting document has expanded discussions of

electrotechnologies specific to this sector and identified additional

conservation techniques. The ability to report the results of an

activity is not dependent on whether a technology or technique is

mentioned in the guidelines or supporting documents.

4. Transportation

In addition to the general revisions discussed above, DOE has

expanded the discussion on electric vehicles in the Transportation

Sector supporting document. Activities in the transportation sector are

characterized by an extensive array of measurement and estimation

methodologies, some of which are mentioned in the document. The use of

some of these methodologies is required under various Federal

regulatory and funding programs, such as those which regulate vehicle

air pollutant emissions or award highway construction funds. For the

reasons discussed above, reporters are not limited to using these

protocols.

5. Forestry

Comments on the Forestry Sector document related to its apparent

emphasis on carbon sequestration activity from new or replacement

forestation, together with a corresponding lack of emphasis on forest

preservation, forest management, and urban forestry. The varying

treatment of types of carbon sequestration activity is not meant to

imply a preference by DOE, or by the reporting program, for any

particular type of forestry activity. It is, rather, based primarily on

the state of the knowledge in these areas of forest carbon

sequestration. Similar to other sector documents, reporting is not

limited to the activities discussed.

Comments on the limited tree species and associated reference cases

provided for standard forestry projects suggested that the table be

expanded to include additional species. These data were developed with

the assistance of U.S. Forest Service staff, and the tables are based

on the availability of sufficient information to generalize carbon

sequestration effects of certain activities. While such information is

available for the major commercial species which are addressed in the

tables, DOE believes that there is insufficient information available

to develop adequate default tables on other species or reference cases.

For additional species and reference cases, as well as for other

forestry activities, the reporter will need to develop specific project

data.

Other commenters stated that field measurements for projects in

this sector were particularly essential to assure the accuracy of the

data submitted. Consistent with the flexibility necessary to encourage

reporting in this and all other sectors, the guidelines do not provide

prescriptive features such as requiring field measurements. Rather, the

guidelines indicate that a reporter will be asked to categorize the

data submitted, including whether it is based on measurement.

6. Agricultural

Comments received on the draft document for the Agricultural Sector

were indicative of the complexity of the sector, and its unique

characteristic of including reportable activities that contribute both

to greenhouse gas emissions and to carbon sequestration.

Comments were received on the failure to include any discussion of

certain emissions reduction or carbon sequestration approaches

specifically applicable to the agricultural sector. In response to

these comments, additional text has been added on windbreaks and

shelterbelts, changes to grazing land, and the production of biomass

for fuel. The failure of the document to address other agricultural

activities which affect greenhouse gases or carbon sequestration is not

intended to preclude data submissions on those activities, including

energy efficiency improvements.

7. Adjusted Electricity Emissions Factors by State

Substantial and detailed comment was received on the draft Appendix

C, ``Adjusted Electricity Emissions by State,'' which appeared in all

draft sector supporting documents. After consideration of the comments

received, Appendix C has been revised to employ a simpler methodology

and the inclusion of nonutility generation emissions. A summary of the

methodology used for the table appears together with the table in

Appendix C. The published data on fuel use and technologies used are

identified.

In response to comments that the draft failed to include nonutility

generation, emissions factors for nonutility generation have been

added, together with weighted combined emissions factors for utility

and nonutility generation. Where the reporter utilizing the table knows

whether the power is utility or nonutility generated, the appropriate

factor should be used. The combined factor is intended for use when the

reporter is unable to make this identification.

In keeping with the flexibility of the program, reporters are

encouraged to use emissions factors specifically applicable to the

project being reported. Where a utility-specific factor is available,

for example, it will incorporate actual fuel mix and dispatching modes

which are not differentiated within a State factor provided in Appendix

C. The inclusion of revised Appendix C is in keeping with the

programmatic goal of maximum participation, by providing a method for

estimating emissions and reductions when other data are not easily

available.

III. Administrative Requirements

A. Regulatory Review

DOE has determined that this is not a significant regulatory action

because it does not meet the criteria which define such actions under

Executive Order 12866, 58 FR 51735, and is therefore not subject to

regulatory review. Accordingly, the Office of Management and Budget

(OMB) has informed DOE that no clearance of the guidelines and

supporting materials is required.

B. Issues Under the Paperwork Reduction Act

The provisions of section 1605(b) direct EIA to develop the

reporting forms and database for the reporting program, consistent with

the guidelines issued today. Separate administrative requirements apply

to the development of EIA reporting forms.

Any information collection requirements proposed for the voluntary

reporting program are subject to the Paperwork Reduction Act, 44 U.S.C.

3501 et seq., and will be submitted to the Office of Management and

Budget for review and approval of paperwork requirements. EIA

anticipates the availability of draft reporting forms for public

comment within 30 days. A notice on the availability of the draft

reporting forms will appear in the Federal Register.

Issued in Washington, DC on October 13, 1994.

Susan F. Tierney,

Assistant Secretary, Office of Policy.

[FR Doc. 94-25901 Filed 10-18-94; 8:45 am]

BILLING CODE 6450-01-P