Hundreds of colleges and universities in the United States, from community colleges to doctoral degree granting research institutions have begun to measure their greenhouse gas emissions. Whether the impetus for this first arose after becoming a signatory to the American College & University Presidents’ Climate Commitment (ACUPCC) or for other reasons, the process of measuring and quantifying the emissions from a campus is one step in the path towards (hopefully) reducing those emissions.

Many campuses find the task of doing a greenhouse gas emissions inventory fairly straightforward. With the availability of Clean Air – Cool Planet’s Campus Carbon Calculator  (which is free for campuses), along with hundreds of other campuses to look to for examples, there are few barriers for a campus to overcome besides finding passionate staff, faculty or students who have the time to complete the inventory. Increasingly, only one area continues to cause heart burn and anguish: measuring those elusive Scope 3 emissions sources. A new proposed rule for Scope 3 emissions may make the task even harder. The World Resources Institute has released a revised draft guide for accounting for scope 3 emissions that is being tested by, 60 corporations. Unfortunately, there are no campuses participating in the pilot. This new draft framework could have important implications for campuses currently tracking various scope 3 emissions sources. See the press release here announcing the new framework.

Institutions participating in the ACUPCC are required to include two types of scope 3 emissions in their inventories: those from air travel paid for by or through the institution and from regular commuting to and from campus by faculty, staff and students (to the extent data is available). The ACUPCC also requires that greenhouse gas emissions inventories be consistent with the standards of the Greenhouse Gas Protocol (GHG Protocol) of the World Business Council for Sustainable Development (WBCSD) and the World Resources Institute (WRI).

There is tangible evidence that these scope 3 emissions sources are a significant emissions source for many institutions. For example, emissions from commuting comprise around 50% of total emissions for the average associate's or tribal colleges. See the data view of average gross emissions by source from campuses that are participating in the ACUPCC.

The largest proposed change is the requirement that in order to be in compliance, an entity must report all scope 3 emission sources that combined make up at least 80% of the total emissions from those scope 3 sources. In other words, institutions could not report emissions from commuting and air travel but leave out emissions from outsourced activities, supplier manufacturing, or any other emissions included in scope 3 and still remain in compliance. Clearly this poses a problem and seems to be in many ways counterproductive: does it really make sense in a campus setting to require an evaluation of all scope 3 sources before reporting on any one of them in order to be in compliance with WRI standards? It seems like this provision is likely to lead to campuses just deciding not to evaluate any Scope 3 emissions. The problems are only compounded due to the difficulty in determining where scope 3 emissions sources end for educational institutions. Do the emissions associated with higher education's "products" (i.e. graduating students) count? How about emissions associated with our "raw materials" (i.e. incoming students). Many campuses already have difficulty calculating emissions associated with air travel and commuting, and this new standard appears to only complicate what many consider the “least methodical, quantifiable part of our emissions footprint”.

The comment period on the current draft has passed, but I do encourage campus sustainability professionals to read it and be prepared to submit comments in the next round coming up in June. I would also be interested to hear what your initial thoughts are on it; please feel free to post any comments or questions in the comments section below.

 Update:The ACUPCC Program Team has clarified that the proposed changes to the GHG Protocol will not impact the ACUPCC reporting sources, and there are no plans to modify the scopes covered by the ACUPCC – namely Scopes 1 and 2; and institution-paid air-travel and regular commuting from Scope 3 – as laid out in the ACUPCC Implementation Guide. The ACUPCC will continue to refer to the current version of the GHG Protocol if a new version is released, unless the ACUPCC Steering Committee decides to modify the scope of emissions sources covered, and this would only take place after extensive input and support from the ACUPCC signatory network.