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California's Global Warming Solution Act of 2006 mandates that facilities emitting more than 25,000 metric tons of carbon dioxide equivalents annually from stationary combustion must report emissions starting this year. This could affect public agencies that have diesel generators, landfill gas flares, wastewater digester gas combustion, water pump engines, and/or green waste grinders. It's also likely that the rule will be extended in the future to cover more specific sources — such as landfills.

When California passed the Global Warming Solutions Act of 2006, the landmark legislation imposed the nation's toughest restrictions on greenhouse gas emissions and provided a template for the U.S. EPA, other states, and the rest of the world seeking to develop similar programs.

To facilitate the goal of reducing emissions by 30% to 1990 levels by 2020, the law combines regulatory enforcement, such as mandatory reporting, with market measures including a cap-and-trade program that will become part of a regional carbon market and cover 85% of the state's emissions. Calculating and tracking emissions and reductions is the foundation for the program's ultimate success, and represents the first — and most challenging — step for public agencies.

2008 is the first year agencies must report emissions, which means they must report 2008 emissions by April 2009. Subsequent years will be reported in the year immediately following.

So far the rule applies only to facilities that emit more than 25,000 metric tons of carbon dioxide equivalents (MTCO2E) annually from stationary combustion and/or generate and sell 1 MW of electricity. Therefore, the mandatory reporting rule primarily affects the power sector and facilities that have stationary combustion sources. However, 25,000 MTCO2E is a relatively low threshold for combustion sources, and can easily be exceeded by public agencies that have diesel generators, landfill gas flares, waste-water digester gas combustion, water pump engines, and/or green waste grinders. It's also likely that the rule will be extended in the future to cover more specific sources — such as a wastewater treatment plant or a landfill — and/or lower the emission threshold, which would capture more public agencies in the program

To determine whether they'll be subject to mandatory reporting requirements, public agencies should calculate their 2008 emissions from specified sources — including all stationary combustion sources and sources previously deemed portable — from each of their facilities and compare it with the 25,000 MTCO2E threshold. In addition, they must evaluate any electricity they generate and sell to the power grid. If the generated power is used directly by the agency, it may be exempt from reporting. Operations that include internal use of generated power but sells power to a utility when certain equipment or operations are off line, or when there is excess power, may need to consult an expert to assess applicability.

HOW TO INVENTORY OPERATIONS

The law sets emission caps, and will ultimately determine reductions goals, based on 1990 emissions levels, so it is critical for agencies to develop a 1990 emissions estimate. An agency can use another year if it didn't exist then, has completely reorganized, or, in some cases, hasn't retained the necessary records. But if it has dramatically upgraded facilities for energy conservation, switched to alternative-fuel vehicles, or even implemented ride-sharing, using 1990 or as early a year as possible as the baseline is the way to go because it demonstrates how much progress has been made in reducing emissions.

If an agency doesn't have records from 1990, managers will have to “scale” — find a year for which they have data and look at the direct relationship between emissions and another operational parameter, such as material usage, number of personnel, square feet of office space, or population served. Scaling isn't as accurate as working from reliable data, but sometimes it's the only way to calculate emissions for years when no or little data are available. However, these calculations could be significantly off because they don't account for changes in consumption, efficiency, and other criteria from year to year.

Agencies should determine their baseline emissions and subtract that number from the levels they're producing when the cap-and-trade program begins. The difference will be the carbon footprint reductions most-likely needed to comply with the 2020 threshold for any sources subject to the cap.

Whether they run a wastewater treatment plant or landfill or their employees drive government-owned vehicles, agencies must estimate how much carbon dioxide they've been putting into the atmosphere through daily operations.

They have to think back to 1990 to identify missing data. What kind of records do they have? Where are they? Who has access to them? Who remembers what happened then?