EPA's GHG Reporting Rule

Gerry, yes, I do think you'll want to track your inputs by month (just because that's probably the easiest way), calculate the amounts and types of emissions those would produce, and once a year combine those numbers and report them to the EPA through whatever reporting mechanism they develop. Remember, you only have to report if your school has a facility on campus that produces 25,000 metric tons CO2e per year. Some schools who haven't done any GHG inventories will have to measure for a few years anyway to determine if they do meet that threshold or not.

To summarize the Green Schools November ’09 discussion:
Carol Dollard in Facilities Mgmt at Colorado State U. began by bringing up some concerns. First, that the EPA’s reporting requirements were calendar-year based while the ACUPCC’s requirements were school-year or fiscal-year based. In fact, as Mike Lizotte, Director of Sustainability at the University of Wisconsin Oshkosh pointed out, the ACUPCC allows either fiscal year OR calendar-year reporting, but does ask that schools remain consistent either way. A few people who prefer calendar year reporting for the ACUPCC listed these reasons:

-- ACUPCC is listing reports by year (e.g. 2008), not school year (07-08 or 08-09?);
-- comparisons and integration with city, county, state, US, vendors, etc.
-- different fiscal year start/end dates (e.g. July 1 versus federal Oct 1)
-- The Climate Registry requires reporting by calendar year.  TCR is the closest thing that existed, previous to the EPA regs, to a national standard.  It's pretty consistent (or at least tries hard to be) with international standards, as well.  By moving toward a single standard, we can help promote inventories which are readily additive (that is, which can readily be summed by geographic area, by industrial sector, by whatever dimension is of interest) rather than difficult even to compare.

Carol was also concerned about the differences in which Scopes are required between the ACUPCC and the EPA’s regulation (Scope 1 only to EPA, Scopes 1,2, and 3 to the ACUPCC), and how that would affect ease of reporting and constituents’ perceptions of the two different numbers schools were putting out. She said, “These numbers will differ vastly and the difference will only be easy to explain to us "GHG nerds" that understand what Scopes are.  Any plans on ways to clarify these discrepancies for the folks who aren't as mired in this stuff as some of us?”

Rick Martin replied, “For protocols which are attempting to set up a comprehensive inventory scheme more than to educate, including only Scopes 1 and 2 makes sense -- Scope 1, because that's stuff you're burning yourself; Scope 2 because while the actual GHGs aren't being generated on your property, you have more control of demand levels than the utility companies do.

And for regulatory schemes (like the EPA regs), Scope 1 is where it's at.  (Remember, your Scope 2 emissions are the utility company's Scope 1.  Regulations focusing attention strictly on Scope 1 incent the utility companies to get cleaner which, in the longer term, will amplify any savings generated at the consumer end.)

My hope is that campuses will focus on the PCC number, and not be concerned if other numbers are reported to other agencies/repositories.  That way, differences can remain in the realm of GHG nerds like me.”