Emissions Transparency: High Priority for the US in Durban, Lower Priority at Home?

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Most data about the amount of greenhouse gases being emitted into the atmosphere don’t come from direct measurements out of smokestacks; instead, they come from calculations made from input data* provided by energy producers and consumers, and corresponding emission factors.** Without information about the various input data underlying emissions calculations, it is very difficult to evaluate the accuracy of emissions figures.

At the 17th meeting of the Conference of the Parties (COP-17) of the United Nations Framework Convention on Climate Change (UNFCCC) in Durban, South Africa, underway right now (28 November – 9 December 2011), the US government is pressing for high transparency standards for developing countries in their reporting of greenhouse gas emissions and their actions to slow global warming.  WWF is closely following this issue, and supports better reporting by developing and developed countries, as stated in our position on the topic for Durban.

However, the Obama administration is not as enthusiastic about transparency for the U.S. as it is for other countries. The Environmental Protection Agency (EPA) is implementing the Mandatory Reporting of Greenhouse Gases rule for individual facilities. However, the environmental community is concerned about the ability of the EPA to verify the quality of the data provided by companies, since the agency deferred until 2013 and 2015 the reporting of many inputs used to calculate carbon emissions.  In other words, the EPA won’t have access to a lot of the background data necessary to verify the final calculations of emissions provided by individual industries. 

The delay was based on concerns about confidentiality as many of those inputs may qualify as “Confidential Business Information,” needing a specific review to determine that their public release doesn’t undermine the competitiveness of each company. The EPA argues that it will still be able to verify the emissions data electronically and detect mistakes, and will conduct audits and checks on facilities about their reports. However, without key data used to calculate emissions, more subtle misreporting or mistakes in the data will be much harder to detect between now and 2015.

On October 24, 2011, several organizations (Sierra Club, Environmental Defense Fund, Natural Resources Defense Council, Clean Air Task Force and the Center for Biological Diversity) presented a petition to the EPA to reconsider this deferral, on the grounds that it severely limits EPA’s and the public’s ability to verify and trust the emissions data reported by companies. This is in line with what WWF recommended in our June 2010 report about emissions inventories in the US and China. In that report, we indicated that the US could actually learn from China, where audits and spot checks are regularly carried out on industries to validate energy consumption data.

Need for Transparency on Both Fronts

In summary, if the US wants to be credible in Durban on this issue, it needs to uphold the same high standards of transparency with the Mandatory GHG Reporting Rule at the national level. By reconsidering the unwarranted delay by the EPA in reporting of inputs to emissions calculations, the US will correct deficiencies in its reporting program and make it much more solid and credible. Clarity and not murkiness is what the world demands for curbing global emissions and preventing the worst impacts from a changing climate.


* Or “Activity Data” as defined by the IPCC: Data on the magnitude of a human activity resulting in emissions or removals taking place during a given period of time. Data on energy use, metal production, land areas, management systems, lime and fertilizer use and waste arisings are examples of activity data.

** As defined by the IPCC: A coefficient that quantifies the emissions or removals of a gas per unit activity. Emission factors are often based on a sample of measurement data, averaged to develop a representative rate of emission for a given activity level under a given set of operating conditions.

Online Resources

EPA. Greenhouse Gas Reporting Program.

EPA. Factsheet.  Factsheet. Mandatory Reporting of Greenhouse Gases (40 CFR part 98). June 2011

E&E TV. Former EPA climate director Kruger discusses future of air rules, GHG reporting program. September 9, 2011.

Amy Mall. EPA issues new rule requiring reporting of greenhouse gas emissions from the oil and gas industry. Switchboard, Natural Resources Defense Council staff blog. November 24, 2010

OMB Watch. EPA both increases and delays public access to critical greenhouse gas data. September 13, 2011.

UNFCCC. Views on the items relating to a work programme for the development of modalities and guidelines listed in decision 1/CP.16, paragraph 66. Submission by the United States of America. September 2011.

WWF. Counting the Gigatonnes: Building trust in greenhouse gas inventories from the United States and China. June 2010 (Revised September 2010)

WWF International. WWF submission on Measuring, Reporting and Verification [to the UNFCCC]. September 9, 2011.

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