**COMMENTS ON INTERIM FINAL GENERAL GUIDELINES AND DRAFT TECHNICAL
GUIDELINES FOR VOLUNTARY GREENHOUSE GAS REPORTING (FR 15169, Vol. 70,
5/24/2005)**

**Start Year**

As stated in the preamble, (FR 15171, Vol 70, 5/24/2005), *"...the
1605(b) program will serve as the primary public emission and emission
reduction reporting mechanism for participants in EPA's Climate Leaders
program and in DOE's Climate VISION program."* Therefore, it is
important that the 1605(b) guidelines be consistent with the
requirements for participants in the Climate VISION program. The Salt
River Project (SRP) is a co-signatory to the Power Partners agreement
which lays out a 2012 sectoral target for reduction in emissions
intensity by 3-5% when compared to the period 2000-2002.

The 1605(b) guidelines state that the first year of calculated
reductions must be the year immediately following the Start Year. SRP
might wish to choose 2000-2002 as the base period, in order to be
consistent with the base period in the Power Partners agreement.
However, SRP may not have any reductions to either report or register in
the years 2003-2005. If, for the sake of argument, the first year of
reductions is in the year 2006, the guidelines indicate that the base
period would have to end in 2005. The year 2005 should then be
designated as the Start Year. Clearly, in this case, there is a mismatch
between the Power Partners base period (2000-2002) and the 1605(b) Start
Year (2005). Under these guidelines, SRP would have to consider separate
base periods for Power Partners and 1605(b). SRP urges DOE to evaluate
this inconsistency, and make changes necessary to reduce the reporting
burden for entities like SRP who may have an interest in participating
in Power Partners as well as 1605(b). From the discussions provided in
the guidelines and in the workshop transcripts, the utility of setting
the Start Year as the year immediately preceding the first year of
calculated reductions is not immediately apparent. Removing that
constraint should not affect the accountability needed in calculating
reductions.

**Avoided Emissions, Off-system Reductions**

Under the current Guidelines, only generators of renewable energy can
register reductions from avoided emissions. The current system should be
revised to allow utilities to register avoided emissions associated with
purchases of renewable energy.

Similarly, utilities should be allowed to register reductions associated
with the avoided emissions caused by investment in Demand Side
Management programs, and sale of coal ash for reuse.

The current system only allows entities to register reductions occurring
within their domain. However, in many cases, companies invest in
greenhouse gas reduction projects that occur outside their boundary.
Companies should be allowed to register reductions associated with such
off-system investments. In the absence of registered off-system
reductions, it would be quite difficult to compile an accurate record of
company commitments to control greenhouse gas emissions.

Finally, in many cases, projects resulting in emission reductions will
have multiple participants. For example, in a landfill gas to energy
project, the landfill may be owned by one entity, the gas by a second
entity, and the engines by a third entity. In such a scenario, it
becomes hard to identify the true "owner" of the avoided emissions. To
address this scenario and others identified in this section, it might
perhaps be possible to design the Guidelines in such a manner as to
allow for registration based on reduction "ownership" ratios defined in
contracts between the parties cooperating in projects leading to
emission reductions.

Avoided emissions from renewable energy, Demand Side Management, coal
ash reuse, landfill gas to energy; and off-system projects, are all
important components of utility greenhouse gas management plans.
Therefore, it is important that the 1605(b) accounting system be
designed in a manner that will accurately represent such plans.