WCI to close public comment on mandatory GHG reporting policy June 4
The Western Climate Initiative (WCI) will close the public comment period on its “Final Draft Essential Requirements of Mandatory Reporting for the WCI this Thursday, June 4. The Final Draft and Response to Stakeholder Comments, made available together on May 8, 2009, describe both WCI’s responses to prior public comment (regarding its January 2009 greenhouse gas reporting requirements) and the changes it made in response to those comments.
Although the report informs the public of changes WCI considered in response to public comment, recommended changes to key policy details were largely rejected. For instance, “many commenters” expressed concern that the reporting and verification thresholds (e.g., 25,000 metric tons of CO2e for the cap and trade program; 10,000 metric tons of CO2e for mandatory emissions reporting) were too low and that third-party verification of emissions reports was unnecessary.
With regard to the threshold comments, WCI responded:
The choice of the cap-and-trade program threshold was made after analysis of estimated facility-level emissions and was designed to ensure capture of 85-90% of WCI Partner jurisdiction emissions. Raising this threshold to 50,000 or 100,000 metric tons … would incentivize “leakage” of emissions to smaller facilities within an industry. The reporting threshold was set at a lower level to allow monitoring of uncapped sources for “leakage”, to allow WCI Partner jurisdictions to check for avoidance of the cap by facilities underestimating their emissions . . .. WCI expects that many of the facilities . . . in the 10,000 to 25,000 metric tons of CO2e emissions range will have only simple combustion sources [for which] emissions quantification … will be fairly simple.
In response to the verification comments, WCI stated that it “still firmly believes that third party verification is necessary” and that after “examining the experience of other GHG programs, WCI has found that third party verification is a cornerstone of national and international GHG reporting protocols.” WCI also rejected calls for reporter exemptions for CO2 emissions from biomass combustion. However, WCI did agree to relax the blanket requirement for a full verification if a reporter engaged a new verifier merely due to a change in verifier personnel.
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