Campus Ecology - Campus Ecology - National Wildlife Federation

Proposed Changes in Emissions Counting Concern Some Colleges

Ryan Newhouse

May 18, 2010

Since launching in December 2006, 685 colleges and universities have signed the Presidents' Climate Commitment (ACUPCC). Schools on the list have set greenhouse gas (GHG) emission reduction targets, ultimately aiming at climate neutrality, and schools have since been rolling along toward those goals as quickly as they can staff for them. A new proposed rule for measuring a school's Scope 3 emissions, however, risks overburdening those tasked with making a difference on campus.

When a school signs the ACUPCC, it agrees that within one year the school will complete a comprehensive inventory of greenhouse gas emissions and then update the inventory every other year thereafter. The school also agrees that within two years of signing, it will develop a climate action plan for becoming climate neutral as soon as possible.

An integral part of the GHG inventory is to establish a baseline level of the school's GHG emissions. While many schools attempt to chart emissions back to 1990, most pick a recent year's known emissions and set it as its baseline. When a school looks at its GHG emissions, it focuses on three specific "scopes," or boundaries.

Scope 1 emissions are direct emissions, which are those directly occurring from sources controlled or owned by the school, such as fossil fuels burned in fleet vehicles and on-campus heating and cooling.

Scope 2 emissions are imported emissions, and they include indirect emissions from the production of purchased electricity and steam.

Scope 3 emissions are comprised of all other indirect emissions that are "a consequence of the activities of the institution, but occur from sources not owned or controlled by the institution," according to the ACUPCC Implementation Guide. Scope 3 emissions include air travel for school activities, waste disposal, food and embodied emissions from purchased goods (i.e. "upstream" costs).

Scope 3 emissions are often very difficult to measure, as the actual emissions may take place in another country or continent. There is also debate as to where Scope 3 sources end at a university, especially if one were to consider graduating students a "product" of the institution, or incoming freshmen as "raw materials."

As an ACUPCC signatory, a school must include in its inventory all Scope 1 and 2 emissions, but only commuter and air travel and waste disposal emissions from Scope 3 sources, which are by far the easiest to identify, measure and address.

However, the World Resources Institute (WRI) has proposed a significant change in its recently revised draft of the GHG Protocol (developed by WRI in partnership with the World Business Council for Sustainable Development) that would require an entity to report all Scope 3 emission sources that, combined, account for at least 80 percent of the total emissions from Scope 3 sources, thus no longer allowing schools to leave out the outsourced activities and "upstream" emissions from product purchases.

Signatories of the ACUPCC are currently required to use the WRI's GHG Protocol for measuring Scope 3 emissions, but to keep up with this change will require a considerable increase in workload for campus personnel. The first draft of the GHG Protocol was released last November and included a public comment period in January. A second draft, according to WRI, is due this coming September and will include another opportunity for public comment. (This date is later than several published articles indicating that a public comment period is scheduled for June 2010).

Scope 3 emissions do make up a substantial portion of a school's overall impact. According to an exercise directed by Fahmida Ahmed, former Sustainability Specialist for UC Berkeley, an inventory total would more than double if all indirect Scope 3 emissions were counted.

And according to the ACUPCC, commuting alone accounts for 24 percent of the average gross emissions at master's colleges and universities. That total jumps up to 51 percent for associate's and tribal colleges.

Without the proposed change, the emissions inventory process is mostly straightforward, thanks in large part to the availability of reporting tools like the "Campus Carbon Calculator," developed by Clean Air-Cool Planet, and the Climate Registry. The "carbon calculator" is consistent with the current GHG Protocol and allows campus sustainability staff to crunch numbers relatively easily using database-driven software.

The ACUPCC claims that regardless if WRI passes the proposed change to the GHG Protocol, signatories will see zero impact on their emission reporting requirements unless the ACUPCC Steering Committee decides to start requiring schools to adhere to the updated GHG Protocol for Scope 3 emissions, which currently the Steering Committee is not planning to do.

Matthew St. Clair, sustainability manager for the University of California's Office of the President, looks back on the history of WRI's reporting methods and the role they have played in a university setting, but he is yet to review all the details of the proposed changes.

"At the time [ACUPCC started]," says St. Clair, "the WRI methods were useful tools for the ACUPCC to use for tracking and measuring."

However, "WRI did not have any universities in mind when they created these reporting methods," continues St. Clair. "They were prepared solely for use by the private sector."

St. Clair isn't sure if there is enough weight in the university scene to change the new reporting rules. "I don't know if the higher education section is large enough," says St. Clair, "that WRI has considered making any accommodations in their reporting standards."

WRI declined to comment about the new proposed rules for Scope 3 emissions. However, the organization would discuss a "road test" it began in January with over 60 corporations that started measuring their emissions with the new Scope 3 GHG Protocol Standard and Product Life Cycle Accounting and Reporting Standard.

"The feedback the companies give us [in June] will be taken into consideration for revisions," says Cynthia Cummis, Senior Associate with the GHG Protocol team at WRI.

One could note, however, that no universities or colleges are represented in WRI's list of "road testing" corporations for the Scope 3 Protocol Standard.

"Our process was an open solicitation for road testers that was publicly announced," says Cummis, "and then we asked for expressions of interest. We were looking for a diverse group of organizations and sectors and representation geographically. I actually don't think we got any universities to apply, so it's not as though we excluded them. I think they did not express interest. We would have been happy to have them participate."

WRI expects to publish the final text of the new standards by the end of 2010, following the release of the second draft in September and public comment period in October.

Campus representatives are encouraged to sign up as members of the Stakeholder Advisory Group for the Greenhouse Gas Protocol Initiative.