Frequently Asked Questions (FAQ) about the Draft Local Government GHG Protocol
ICLEI and our partners are working hard on a number of initiatives that will impact our member’s greenhouse gas quantification work. While these projects are currently in process, ICLEI is striving to minimize uncertainty and make the most relevant and up-to-date information available to our members throughout the United States and provide the best guidance possible.
Background
International Local Government Greenhouse Gas Emissions Analysis Protocol
The International Local Government Greenhouse Gas Emissions Analysis Protocol is a guidance document which provides a basic framework for consistent quantification and categorization of greenhouse gas emissions at a local government level. It is intended to be applicable for use by any local government around the globe.
ICLEI has conducted a peer review process drawing upon the expertise and experience of a network of peer organizations and our worldwide membership of over 800 local governments. We are striving for the fullest possible alignment with established protocols to ensure the final Local Government Greenhouse Gas Emissions Analysis Protocol captures the most relevant expertise and sets an informed global standard for local governments conducting climate protection work.
A draft of the International Local Government Greenhouse Gas Emissions Analysis Protocol is available at: www.icleiusa.org/protocol. The final version will be completed this summer.
U.S. Local Government Operations Protocol and Community Guidance
ICLEI has partnered with the California Air Resources Board (CARB), The California Climate Action Registry (CCAR) and The Climate Registry (TCR) to develop a greenhouse gas reporting protocol for local government operations for use in the United States. This process complements and completes ICLEI’s International Local Government GHG Emissions Analysis Protocol. This Protocol will serve as the U.S. specific supplement, operationalizing the general guidance given in the International Protocol.
This is the first of two forthcoming documents; these same partners will expect to begin a similar process to develop guidance on the conduct of emissions inventories at the community scale in August.
These partners have worked closely to create harmonization between GHG inventories developed by members and reporters under these different programs, to promote the important role that local governments can play in combating global climate change, and to advance the consistent, comparable and relevant quantification of GHG emissions by local governments.
- Click here to learn more about the protocol development process
- Click here to see a list of workgroup members who assisted
The following questions and answers are intended to resolve some of the most frequent questions about how these protocols will impact ICLEI members. Undoubtedly, there will be additional questions and as always, ICLEI staff is available on call to help members with these specific questions.
What is the purpose of a local government specific protocol?
- The purpose of this protocol is to provide measurement and reporting guidance specific to the needs and functions of local governments. Existing corporate accounting protocols do not delve into the details of municipal operations such as street lighting, landfill emissions, and fugitive emissions from wastewater treatment. Similarly, the current guidance for geopolitical inventories does not specify down to the city or county level when discussing energy consumption, transportation or waste disposal.
This protocol will provide clarity and consistency among ICLEI members around the country, with other greenhouse gas management programs and with an eye toward complying with potential future regulatory systems.
Should we wait to begin our government operations emissions inventory until after the completion of the U.S. Local Government Operations Protocol?
- No. Climate protection is urgent work. While it would be inappropriate to presuppose the outcome of the process, it is likely that the draft Protocol will closely resemble the final product. It is advisable to proceed with the data collection and data entry based on the existing draft protocol and wait until the finalization of the U.S. Local Government Operations Protocol to publish your final product.
Should we wait to begin our community emissions inventory until after the completion of the U.S. supplement?
- No. Climate protection is urgent work. While there may be some changes in the guidance that ICLEI offers over the coming months, these will be relatively minor. The majority of a community’s emissions will be calculated exactly the same way as they have been for years. The changes that are likely to be proposed will add additional sources to the standard calculation, but these sources will be relatively small in comparison to the total community emissions. Inventories completed using the current methodology will most likely be substantially the same as those under future methodologies in terms of the total emissions.
Emissions factors used for the community inventory should be the same as those provided in the U.S. Local Government Operations Protocol.
I thought ICLEI’s standards were voluntary. How do the protocol’s requirements fit into a voluntary program?
- Local government participation in ICLEI’s programs and adherence to these standards will remain entirely voluntary. These standards are established in order to create greater consistency among ICLEI members, with other greenhouse gas management programs and with an eye toward complying with potential future regulatory systems. At this time, ICLEI is not proposing a verification mechanism to demonstrate compliance with these standards.
ICLEI will continue to encourage standardization, and most of our members will use this protocol because doing so will help make the impact and importance of their actions clear, because it brings greater rigor to comparative analysis and because it will strengthen local governments’ position in emerging carbon markets. However, we acknowledge that some governments will have a valid rational for doing their inventory in another way and may choose to deviate from these standards on a case by case basis.
What are emissions scopes and how will they impact local government inventories?
- Under the new protocol, emissions will be classified into three scopes established in the World Resource Institute’s WRI’s Greenhouse Gas Protocol. Scope 1 emissions are direct emissions such as tailpipe or smokestack emissions. Scope 2 emissions are indirect emissions from electricity and central heating and cooling systems where control of the use of the energy rests with the end user even though the powerplant is owned and operated by someone else. Scope 3 emissions are all other indirect emissions sources over which some control may be exerted. This system allows for greater certainty that double counting has been prevented while simultaneously allowing for the inclusion of sources over which local governments have the most control. The new protocol reporting standards will require the inclusion of all Scope 1 and 2 sources and encourages several optional Scope 3 sources. Under ICLEI’s previous guidance local governments were encouraged to include the same sources but emissions had not been categorized by scope. In most cases the delineation of scopes is fairly easy to accomplish using the Clean Air and Climate Protection Software’s reporting function and a simple spreadsheet. Project 2 Degrees is being developed with scopes in mind and will make tracking scopes even easier.
What emissions factors are recommended for electricity in the U.S. Local Government Operations Protocol?
- In order to align with emissions factors in use by the U.S. Environmental Protection Agency, (EPA), and California Climate Action Registry (CCAR), and The Climate Registry (TCR), the new protocols have opted to recommend electricity emissions factors provided by the EPA as part of eGRID as the default factors for use in the U.S. under the Local Government Operations Protocol. The protocol also provides guidance on employing an optional utility-specific emissions factor. The recommendation to use these factors is a change from guidance provided by ICLEI in the past.
ICLEI suggests that members begin to use the eGRID electricity emission factors for inventories of government operations and communities. CACP can be easily updated to utilize these factors. We will be providing guidance on how to implement these changes before the final publication of the U.S. Local Government Operations Protocol. The next CACP update will likely change the default coefficients for electricity to those provided in eGRID. Project 2 Degrees will be released with the updated emission factors.
The use of eGRID factors as the default in most cases will be the change which will most significantly alter the total emissions from previous guidance given by ICLEI. Local governments that have already completed an emissions inventory using the default factors in CACP should see the guidance on updating baselines. Local governments completing inventories using the new factors should remain aware of this change in comparing inventory results to those of their peers.
Will there be other differences between the emission factors recommended in the Protocol and those previously provided in by ICLEI?
- Emissions factors employed in the U.S. Local Government Operations Protocol for fuels other than electricity are based on the best, current, U.S. specific factors available. The emission factors in the Clean Air and Climate Protection (CACP) software are several years older and are based on global averages. For most fuels there are slight differences between the factors employed in CACP and those set as defaults in the U.S. Local Government Operations Protocol. The change between these emissions factors should not dramatically change inventory results but will improve standardization.
The appropriate factors will be incorporated into Project 2 Degrees and will be incorporated into the CACP software update. Until these tools are available, ICLEI recommends the use of the updated factors for all significant fuels in both community and local government operations inventories. Guidance on updating these factors will be made available before the final publication of the U.S. Local Government Operations Protocol. Local governments that have already completed an emissions inventory using the default factors in CACP should see the guidance on updating baselines.
How will the protocol differ from previous inventories of wastewater treatment facilities?
- In the past, ICLEI has provided guidance on including the energy used in wastewater treatment in emissions inventories. While a few of our members have made attempts to include fugitive and process emissions of N2O and methane, most have not due to the lack of availability of a consistent methodology. One of the significant advances of the U.S. Local Government Operations Protocol is the development, through a stakeholder process, of a standard methodology for estimating these emissions. While it is likely that refinements will be made in the future, this is a significant improvement to the overall guidance available.
ICLEI encourages local governments to begin quantifying these emissions as part of future emissions inventories. Local governments which have completed inventories using either a different methodology or which have not included fugitive and process emissions should consider the guidance on updating baselines.
How does the U.S. Local Government Operations Protocol calculate emissions from solid waste and how does this compare to previous guidance given by ICLEI?
- The U.S. Local Government Operations Protocol includes detailed guidance on calculating Scope 1 emissions from solid waste disposal facilities that the government owns or operates. Dependent upon the operating characteristics of the landfill, this may be based on either engineering estimates or modeling. It also acknowledges that there are potential Scope 3 emissions from solid waste generated by a local government, but which may be disposed of at a facility not controlled by that government. Calculation methodologies for estimating these Scope 3 emissions are not provided.
The Clean Air and Climate Protection (CACP) software provides two methodologies for calculating waste emissions from local government operations which roughly correspond to these two categories. The waste-in-place method is based on the U.S. EPA’s LandGEM model for calculating Scope 1 landfill methane. Local governments that control solid waste disposal facilities should begin using the guidance provided in the U.S. Local Government Operations Protocol as an update to this methodology. Local governments which have completed inventories using the waste-in-place method in CACP should consider the guidance on updating baselines.
The methane commitment method embedded in CACP is based on the EPA’s WARM model for calculating lifecycle emissions from waste generation. ICLEI continues to believe that it is important for local governments to consider the generation of waste. However, our experience indicates that it is often very challenging for local governments to find reliable data on the amount of waste generated from local government operations. As such, and in alignment with the general rule that Scope 3 sources of emissions are considered optional, local governments can be in compliance with the Protocol even though they have not included this source of emissions.
In addition, to create consistency with the principle that local government operations should not account for emissions sinks, ICLEI recommends that those governments that calculate Scope three emissions from waste generation using the methane commitment method should modify the coefficient set to eliminate the effect of landfill sequestration. This should be the case in both government operations inventories and community inventories. ICLEI staff can provide guidance on how to make this modification.
What other process and fugitive emissions are accounted for in the U.S. Local Government Operations Protocol?
- The U.S. Local Government Operations Protocol includes accounting methodologies for several sources for which ICLEI has not previously included guidance. Most significantly, methodologies are included for quantification of fugitive emissions from refrigerants in both stationary and mobile sources; most commonly this will be emissions of HFCs from air conditioners and fire suppressants but may also include other gases. ICLEI is currently developing reporting standards to be appended to the U.S. Local Government Operations Protocol. Due to a concern that many local governments will not have data available on these emissions sources, ICLEI expects to make reporting of HFCs, PFCs and SF6 optional for several years to allow governments time to implement tracking mechanisms for these substances. Inclusion of these gases in the first years will be considered good practice, and ICLEI will work with those members who are successful in implementing tracking mechanisms to develop more complete guidance for the rest of the ICLEI network.
What if I can't get all of the data required for calculations in the new protocol?
- The U.S. Local Government Operations Protocol recommends quantification methodologies for all of the emissions sources that are to be included. In most cases one or more than one alternative methodologies are offered for situations in which the data for the recommended methodology is challenging to get.
Additionally, recognizing that some sources of emissions are relatively small but would take a lot of effort to quantify, de minimis allows for up to 5% of the emissions in an inventory to be estimated rather than quantified. ICLEI will provide guidance on de minimis in the reporting standards under development. Many of the sources included in the U.S. Local Government Operations Protocol which were not previously accounted for in CACP will fall into the de minimis category.
What are the implications on existing inventories, established baselines and reinventories?
- Local governments that have already completed emissions inventories and have established these as baselines for their climate protection work may encounter some challenges in incorporating these changes into their greenhouse gas management programs. ICLEI is providing this guidance to assist with that process. As always, ICLEI staff is available to help our members with the technical challenges as well as with the best way to communicate any changes.
How will this affect existing baselines, reduction targets and progress towards them?
- ICLEI expects that in most cases the new protocol will improve the range of options that communities have to achieve their reductions targets. However, we are sensitive that this reporting change will likely affect targets that have been established against the old baseline which was calculated with some differences from how inventories will be calculated moving forward. We encourage local governments to incorporate these changes in ways that do not appear to undermine meaningful, good-faith progress towards their targets.
Local governments that have recently completed inventories should not feel compelled to begin anew using the new Protocol. In the majority of cases, the differences resulting from the changes will be relatively small in comparison to the total emissions figures. Existing inventories are adequate for most voluntary efforts, and redoing the process should not be a top priority for communities that have limited resources to invest in climate protection.
When it is time to conduct a routine reinventory, ICLEI encourages local governments to do so in accordance with the standards in the U.S. Local Government Operations Protocol. In most cases this will only result in a small change from the results that would have been realized under previous guidance. However, we recognize that even a small change can significantly impact progress towards a reduction target. ICLEI stresses that local governments should not claim credit for apparent emissions reductions which are really the result of a change in emissions calculation methodology. Nor should they be held responsible for apparent emissions growth resulting from inclusion of additional sources in their reinventory or changes in emissions factors used.
ICLEI suggests two primary paths for communities that have established baselines and targets and are concerned that a new inventory methodology will impact these:
- Recalculate the baseline - ICLEI considers it good practice, as part of a standard reinventory process, to recalculate the existing baseline and simultaneously recalculate the established reduction targets as a percentage of the recalculated baseline. Local governments that follow this process will generally experience a fairly small increase in the absolute quantity of emissions reductions needed to achieve the target. This is the result of the reduction target being a percentage of a slightly larger baseline. They will also have a larger set of emissions reduction opportunities.
- Establish a new baseline - Due to the fact that in many cases data availability for a historical baseline is limited, many local governments will find it easier to establish a new baseline. Where the previous baseline included a reduction target, the new baseline should also establish a new reduction target and the level of that target should account for the previously established target.
