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.

Agencies can use a consultant accredited by the California Climate Action Registry or The Climate Registry to calculate emissions, or compile their own report that must be verified by a third party accredited by the California Air Resources Board (CARB). Either way, department managers will be answering a lot of questions about financial data. To get started, they need:

  • Utility records for both electricity and fuel use.
  • The number of vehicles and how many miles a year they're driven, and how much fuel was purchased. While they won't have to document employees' commuting miles, agencies may want to start doing so to get a true carbon footprint. They also may have to review employee expense reimbursements, so if they don't track that information in a way that can easily be compiled, it's time to start.
  • An inventory of stationary or portable engines that, for example, back up power, operate pumps, or run equipment that grinds green waste.
  • To treat landfill and wastewater treatment plants as industrial sources, which could include the carbon output of “stacks” and less obvious “fugitive” emissions like leakage from equipment.
  • Indirect emissions — defined as natural gas, electricity, and steam imports or heating and cooling obtained from centralized plants — outside the agency's boundaries.

    As agencies prepare for a baseline audit, they need to think about how to better centralize reporting systems. Record-keeping is critical to compliance. Get to the heart of the data, get a sense of the operation's processes, and evaluate how real the data are.

    There's still some debate about the “cradle-to-grave” reporting of sources, such as offsite waste disposal. Are emissions attributed to the agency or to the company that processes the waste? Questions will arise about where boundaries are drawn with overlapping services and outsourcing. A key determinant is whether the agency has operation and/ or financial control over the source or operation in question. Managers will find themselves wrangling with other departments and agencies trying to protect their turf, particularly where there is shared operations. For the mandatory reporting program, CARB will make any final determinations as to whether certain sources should be included within the agency's boundary or not.

    Another concern is growth: How can an agency reduce emissions to 1990 levels when the population is growing and residents expect essential public services?

    These issues will sort themselves out over time, but wise managers are factoring them into their current baseline emissions calculations.

    Although the data agencies report this year won't affect the carbon market or enable agencies to create reduction credits, CARB will use the figures to develop the cap-and-trade program. Determining which agencies may generate credits and which will need to buy them won't happen in earnest until the program is in place. This isn't expected to happen before 2010, with initial carbon-footprint reductions not required until 2012.

    In the meantime, auditing operations now prepares agencies for future inventories as the laws are fine-tuned on the state and possibly, with a new administration in Washington, D.C., federal levels. And think about how much goodwill California's public agencies can generate by talking about how they're working to reduce their carbon footprint.

    — Patrick Sullivan is senior vice president of SCS Engineers in Sacramento, Calif.

    Agencies subjected to California's mandatory reporting rule must report emissions for the following sources:

  • Direct stationary combustion emissions (generators, other engines, heaters, etc.)
  • Specified process and fugitive emissions (landfill gas flares, digester gas, etc.)
  • Fuel usage by fuel type; biomass fuels separate (diesel, gasoline, etc.)
  • Indirect energy usage — electricity in kWh and thermal in Btu
  • Mobile emissions (optional).
  • Contribution calculations

    The public and private sectors collaborate to pin down an elusive target.