#  ![](media/image1.jpeg){width="0.5868055555555556in" height="0.9736111111111111in"}

September 22, 2006

Mr. Stephen E. Calopedis

U. S. Department of Energy

Energy Information Administration, EI-81

1000 Independence Avenue, S. W.

Washington, D. C. 20585

Submitted by email to:
[stephen.calopedis@eia.doe.gov](mailto:Stephen.calopedis@eia.doe.gov)

**Comments on Instructions for and Form EIA-1605, "Voluntary Reporting
of Greenhouse Gases"**

The American Forest & Paper Association (AF&PA) appreciates the
opportunity to submit comments on the Energy Information
Administration's (EIA's) revised forms and instructions for the 1605(b)
voluntary greenhouse gas registry.[^1] AF&PA, the trade association and
leading voice for the forest products industry, represents over 200
companies and related associations. AF&PA members produce over 80
percent of the wood, paper, and other forest products manufactured in
the United States; our members include both industrial and
non-industrial private land owners, large multi-product producers, and
family-owned facilities.

AF&PA has considerable interest in greenhouse gas related issues. We
participate in the Administration's Climate VISION program. We have
submitted comments at every opportunity on proposed changes to the
voluntary registry, met with the Administration's representatives on
1605(b) issues, and participated in several Department of Energy (DOE)
and Department of Agriculture (USDA) workshops related to 1605(b). The
1605(b) reporting program is important to AF&PA members, and clear,
concise reporting forms will encourage use of the voluntary registry.

AF&PA members commend DOE, USDA, and EIA for recognizing and
appropriately accounting for many of our industry's unique attributes.
Forests and the products that come from them sequester greenhouse gases
from the atmosphere. Additionally, carbon-neutral biomass fuels are a
source of renewable energy, and biomass-based technologies hold much
promise for the future. Our comments largely focus on these areas and
the need to clarify their treatment in the Guidelines and Instructions.

**Sequestration in Forest Products**

**Calculation of Carbon Flux**

AF&PA commends DOE, USDA, and EIA for recognizing the role of wood and
paper products in sequestering carbon from the atmosphere. We think the
agencies are making a valuable contribution to accounting protocol in
setting this precedent. As the industry that creates and produces these
products, the issue of product carbon accounting is of key importance to
us. We have three recommendations -- explained below -- that we think
will improve and clarify the accounting process.

**Use of Product Sequestration Calculation Tool**

AF&PA members highly commend USDA's and DOE's decision to use the
100-year method to estimate the carbon stored in wood and paper
products. Forest products companies around the world have endorsed the
100-year method for products in-use, and working through the
International Council of Forests and Paper Associations (ICFPA), have
developed an easy-to-use calculation tool, which simplifies corporate
calculations.

The ICFPA tool is based on the principles outlined in the Technical
Guidelines and uses Rowe and Phelps decay curves to determine the amount
of carbon remaining in products in-use after 100 years. The tool allows
companies to use their annual production to estimate their contribution
to product sequestration. Using annual production data, a company can
either 1) let the model assign typical uses (and thus life times) to the
production or 2) specify the uses of its products. For example, a mill
that produces lumber can specify that the lumber is used exclusively for
building houses, assign the lumber to a variety of end-uses, or let the
model use statistical averages. Thus the amount of sequestered carbon
can be accurately estimated for products in use.

Additionally, the model is available in a spreadsheet format with a
user-friendly interface that prompts users for data, thus making the
process clear and easy to understand. To simplify the accounting
process, AF&PA recommends that the latest version of the ICFPA
calculation tool be incorporated by reference into the 1605(b)
guidelines and EIA instructions and forms. The tool, which is maintained
by the National Council for Air and Stream Improvement (NCASI), is
available free of charge on their website at NCASI.org.

**Wood Products from Sustainably Managed Forests**

We recommend that DOE's Guidelines and EIA's Instructions make it clear
that the carbon in wood products -- originating from sustainably managed
forests -- can be counted and applied toward emission reductions even
though the landowner may be claiming zero carbon flux in the forest. The
issue is not addressed in the Guidelines.

Section 1.I.3.5 of the Technical Guidelines states that

> "...it is valid to conclude that significant long-term declines in
> forest carbon stocks are unlikely to occur in sustainably managed
> forests when considering all forest carbon pools such as soil, litter,
> biomass and long-lived products."

This statement can be read to imply that long-lived products are part of
the basis for assuming there is no net carbon flux in sustainably
managed forests and thus are not accounted for under carbon flux
changes.

We do not believe this was DOE's intent, as it reduces the ability of
companies to count carbon stored in wood products and also penalizes
sustainable management of forests. The guidelines need to clarify that
the carbon in wood products -- derived from ***all*** third-party
certified sustainably managed forests (including those not directly
reported in the 1605(b) program) -- is eligible to be counted as stored
carbon.

**Landowner and Manufacturer Accounting Responsibility**

Additionally, responsibility for the registration process needs
improvement and clarification. Forest land owners and forest product
manufacturers make important contributions to carbon sequestration, and
the guidelines should recognize those contributions in the 1605(b)
registry by incorporating a market-based approach. The guidelines should
also encourage landowners to engage in sustainable management and third
party certification of forestlands. Providing the landowner and the
manufacturer with the option to determine how, and by which entity,
forest product carbon will be accounted for through a market-based,
transaction centered process will do this.

A market-based option will ensure greater accuracy in all programs that
provide for reporting or registering wood product carbon. It should
reduce associated transaction costs, and most importantly, it will
ensure that there will be no double counting and that market
participants will determine which option is best in any given
transaction.

Further it will allow the entities to execute and document their
decision in currently used purchase and sales agreements or contracts
which conform to the Uniform Commercial Code as it has been adopted in
the various US States. Entities can include specific language in such
agreements or contracts that specify the terms of the carbon accounting,
reporting and/or registration option that they determine as part of
their transaction. Lastly, we believe that this approach will also
encourage market participants to develop standard versions of "option"
language that can readily be used in such transactions, thereby further
reducing carbon-related transaction costs.

**Forest Land Use**

**Requests for Land Use Information**

As specified in the General Guidelines, the proposed EIA forms require
annual reporting of changes in carbon stocks from forestry activities.
Forest owners are allowed to report a default carbon flux of "zero" for
forestlands that are verified through third-party certification as being
sustainably managed. AF&PA agrees with and applauds DOE's decision to
simplify the accounting process based on the value of sustainable forest
management. However, we are concerned that Schedule I (Table 4e) asks
for the ***acres*** of land under the sustainable management program.

AF&PA members continue to be concerned with any request for land-use
information as part of the effort to track carbon flux. It is
inappropriate for DOE to require participants to report on land-use
change as a part of a voluntary greenhouse gas reporting program.
Land-use decisions are based on business needs that are unrelated to
greenhouse gas emissions, and by requesting such data, the federal
government appears to be taking steps that would limit the future use of
private property.

If an entity is specifying that land is sustainbly managed, subject to
third party certification under a recognized forestry management system,
and reporting no net carbon flux, the number of acres involved is
irrelevant. Moreover, the data do not appear to be used for any purpose
in the 1605(b) registry.

AF&PA recommends that the request for acreage included in a sustainable
forestry management program be deleted from the EIA forms.

**Forest Land Restrictions**

AF&PA recommends elimination of the requirement to place conservation
easements or deed restrictions on preservation areas, which are not
subject to harvest. Landowners should have the option to register annual
stock changes (increases and decreases) from the prior year and net
changes from baseline in the same manner as emissions increases and
decreases are reported. In the event that the carbon stocks decrease
below the baseline, no gains would be eligible to be registered until
amounts equal to cumulative amounts below the baseline are replaced.
Also, should the land use be changed for any reason, and the carbon
stocks are not preserved or are reduced, the land owning entity would be
obligated to remove such reductions from the carbon stocks being
reported and registered.

This approach would ensure integrity and transparency in accounting,
preclude increases that are not above the baseline on a cumulative basis
from being registered, create a land-use change audit trail, and still
provide a landowner options for future use of the land. Thus it would
preserve the full value of the land for the landowner.

**Emissions Inventory Issues** \[Schedule I\]

**Biomass Combustion** \[Schedule I, Table B.1.a\]

The instructions appropriately note that CO~2~ emissions from biogenic
fuels ([e.g]{.underline}., bagasse, wood, wood waste, and ethanol) do
not count as anthropogenic emissions. We commend EIA for correcting the
previous version of the forms and omitting biomass CO~2~ emissions from
the direct emissions accounting in Schedule I.

However, AF&PA recommends that the listed examples of biomass fuels
include spent pulping liquor and other biomass-based materials -- which
play a vital role in providing carbon-neutral renewable energy. We
recommend that the list of examples read, "bagasse, ethanol,
biomass-based materials including wood, wood waste, spent pulping
liquors, and coproducts from conversion."

**Biomass and Lime Production** \[Schedule I, Table B.1.c --
Sector-Specific Process Emissions\]

The final General and Technical Guidelines correctly recognize that
CO~2~ emissions resulting from the pulp and paper industry's conversion
of calcium carbonate into lime are biogenic emissions and are not
reported as part of an emissions inventory. To make this clear and aid
users, we recommend that this information be added to the instructions
for reporting on lime production under Sector-Specific Process
Industrial Emissions.

**Emissions Reduction Issues** \[Schedule III\]

**Absolute Emission Reductions Associated with Reductions in Output**

The EIA instructions state that if reporting year output is not equal to
or greater than the base period average output, any emission reductions
can only be *reported* but not *registered*. AF&PA members strongly
recommend that DOE modify the General Guidelines to allow absolute
reductions in emissions to be reported and registered.

Emissions reductions from such closures are real and permanent. It would
strengthen the guidance to fully account for actual decreases in
emissions in the same way that actual increases are accounted for. If
facility closures result in emission reductions, the reductions should
be fully recognized. Failure to recognize such reductions unnecessarily
penalizes businesses that make changes that both reduce greenhouse gas
emissions and improve their ability to compete in an increasingly global
economy.

It should also be noted that closures generally stem from unexpected or
unusual changes in the fundamental factors that adversely affect a
business venture. When this occurs, the business no longer can assume
"business as usual," and is forced to make one-time changes, the most
drastic of which is a facility closure. Indeed, when a company closes a
plant, it is because it can not sustain business as usual as such a
facility.

It is highly unlikely that any benefit derived from the registration of
greenhouse gas emission reductions will influence the opening or closing
of a plant. Excluding reductions in emissions from plant closings
conflicts with the statutory language of the Energy Policy Act of 1992.
As recognized in the preamble to DOE's General Guidelines, the statute
calls for the establishment of procedures for reporting "reductions in
greenhouse gas emissions achieved as a result of...plant or facility
closings."

Additionally, WRI/WBCSD's *Greenhouse Gas Protocol* specifically states
that "the base year emissions should not be adjusted for...plant
closures."[^2] In other words, according to the *Greenhouse Gas
Protocol*, emission reductions associated with plant closures should be
counted as reductions.

Similarly, the ISO/DIS 14064 reflects this position both for facility
closures and reductions in output. To be consistent with these
international protocols and standards, the General Guidelines should
allow for the reporting of emissions reductions from plant closings as
well as from decreases in output.

**Emissions from Combined Heat and Power (CHP)**

AF&PA also commends EIA and DOE for recognizing the benefits of CHP in
avoiding emissions and as an "action specific method" that can reduce
emissions. However, we remain concerned about the equation the DOE
guidelines are using to allocate emissions and characterize the benefits
of CHP.

The method selected by DOE uses a simplified relationship to determine
the fuel used for steam production, and the emissions are calculated
using an emission factor for the fuel. The DOE guidance allocates a
portion of the fuel consumed by the CHP system to heat production based
on a specified efficiency of producing steam (and provides a suggested
default efficiency value of 0.8). The remainder of the CHP fuel
consumption is allocated to electricity production.

The DOE-recommended formulas are:

$$\begin{array}{r}
\text{Fuel Use}_{\text{Thermal}} = \frac{\text{Output}_{\text{Thermal}}}{\text{Efficiency}_{\text{Thermal}}} \\
 \\
\text{Fuel Use}_{\text{Electricity}} = \text{Fuel Use}_{\text{Total}} - \text{Fuel Use}_{\text{Thermal}}
\end{array}$$

GHG emissions associated with each energy output stream from the CHP
system ([e.g]{.underline}., steam and electricity) are computed based on
the allocated fuel use for each energy stream. The appropriate emission
factors for the fuels consumed are based on recommendations in Part C
"Stationary Combustion" of the Technical Guidance.

Although these relationships may return results that are in agreement
with widely accepted methods such as those recommended by WRI/WBCSD[^3],
EPA Climate Leaders[^4], and ICFPA/NCASI[^5], it is possible that for
some CHP system configurations the simplified method recommended by DOE
may result in misleading estimates of emissions corresponding to steam
and electricity production.

For example, it is crucial to recognize that the overall efficiency of a
CHP system is typically higher than that of a simple power boiler
producing steam or of a steam driven condensing turbine that is only
producing electrical power. CHP systems typically either:

> a\) incorporate a steam turbine mated to a generator to reduce steam
> pressure from high (at boiler exit) to low (to meet process
> requirements), thus making use of the energy difference between high
> and low pressure steam that is often wasted in simple steam
> generation, or
>
> b\) utilize the waste heat from a direct-fired gas turbine to produce
> steam rather than venting this heat to the environment.

The "efficiency method" of allocating emissions from CHP systems,
recommended by WRI/WBCSD, EPA Climate Leaders, and ICFPA/NCASI, takes
into account the increased efficiency of CHP systems as reflected in the
formulas recommended for use in this method:

$$\begin{array}{r}
\text{Fuel Use}_{\text{Thermal}} = \frac{\frac{\text{Output}_{\text{Thermal}}}{\text{Efficiency}_{\text{Thermal}}}}{\frac{\text{Output}_{\text{Thermal}}}{\text{Efficiency}_{\text{Thermal}}} + \frac{\text{Output}_{\text{Electricity}}}{\text{Efficiency}_{\text{Electricity}}}} \times \text{Fuel Use}_{\text{Total}} \\
 \\
\text{Fuel Use}_{\text{Electricity}} = \text{Fuel Use}_{\text{Total}} - \text{Fuel Use}_{\text{Thermal}}
\end{array}$$

The primary benefit of the efficiency method is that it forces the
reporting entity to carefully consider the efficiencies of producing
both steam and electricity at conditions corresponding to the boundary
of the CHP system ([e.g]{.underline}., steam at pressures for use in the
process rather than at the boiler exit), and how these efficiencies
affect allocation of emissions among the two energy output streams. (The
WRI/WBCSD guidance does include default efficiencies of 0.8 for steam
generation and 0.35 for electricity production if the actual
efficiencies are not known.)

AF&PA recommends that the DOE guidelines be amended to include use of
the more widely accepted and more balanced equation, which has been
endorsed by WRI/WBCSD, EPA Climate Leaders, and ICFPA/NCASI.

**Simplified Emissions Inventory Tool (SEIT)**

We are pleased that EIA has included an emissions inventory spreadsheet
with the instructions and forms. This is extremely helpful to users. We
recommend, however, that EIA and DOE continue to accept comments on the
tool for an extended period of time. We think the most valuable feedback
will be developed when the tool is put to actual use.

**Technical Corrections**

AF&PA has also identified several technical corrections or improvements
that would make the EIA forms and instructions easier to use. These are
shown in Attachment A.

Additionally, we have found several technical corrections that need to
be made to DOE's March 2006 Technical Guidelines. These are shown in
Attachment B.

Again, we appreciate the opportunity to submit comments on the EIA forms
and related policy issues. If you have any questions about our comments,
please contact me at 202-463-2588.

Sincerely,

![](media/image2.png)

> Timothy Hunt
>
> Senior Director, Air Quality Programs

cc: Mark Friedrichs, DOE

Bill Hohenstein, USDA

**Attachment A: Technical Corrections or User Improvements to EIA
Forms**

**Schedule I:**

Section 1, question 9 -- There is no need for companies to determine
whether their operations are "nationwide" -- defined as having at least
one operation in each of the 10 census regions. DOE can determine this
by looking at the states where the company operates.

Section 1, question10 -- Scope of Inventory -- Landfill fugitive and
WWTP methane emissions are subcategories of Industrial Process
emissions, however this is not clear from the list of check boxes for
this item. The instructions should clearly identify what category these
emissions should be reported under.

Section 2, Part A, questions/table 1 -- Direct emissions of PFCs, HFCs
and SF6 are not specifically listed in the table. The instructions say
"If you are entering direct emissions of other gases (HFCs, PFCs of
SF6)..." Someone unfamiliar with the general and technical guidelines
will take this to mean that the reporting of these three gases is
optional, and it is not. The guidelines are clear in requiring that
inventories address these gases unless the emissions are de minimis.

Section 2, Part B, questions/table 1 -- There is ambiguity about where
(or even if) to report HFCs, PFCs where these are from stationary
refrigeration or air conditions systems (mobile air conditioning is
specifically identified, however). This could be addressed by modifying
the table and instructions to specifically mention HFCs and PFCs used in
stationary air conditioning and refrigeration systems.

Section 2, Part B, question 1c -- Industrial Processes -- The discussion
of emissions from lime production should explicitly state that
calcination of lime in the chemical recovery process of the Kraft pulp
industry should not be included in emission inventories.

Section 2, Part B, question 3 -- Other Indirect Emissions -- "Other
indirect emissions" are not to be included in an entity's emission
inventory. It may be beneficial to indicate this in a footnote to the
table.

Section 2, Part B, questions/table 4g -- "other terrestrial carbon
fluxes" -- Companies participating in 1605b are being required to report
methane emissions from mill-owned landfills but are not being given
credit for carbon sequestration in these same landfills. DOE and EIA
need to allow for reporting sequestration in company owned landfills.

Section 2, Part B, questions/table 4h -- It would help prevent errors
and confusion if a "zero" was entered in the table in the area for stock
change (or flux) for sustainably managed forests.

Section 2, Part C, question 1 -- Direct Emissions -- The instructions
should restate that biomass CO~2~ emissions should not be included in
the total direct emissions.

**Schedule II:**

Section 1, question 7. -- Again, we see no need to require companies to
determine if they are "nationwide" operations.

Section 1, question 10, Scope of Inventory for Subentities -- Landfill
fugitive and WWTP methane emissions are subcategories of Industrial
Process emissions, however this is not clear from the list of check
boxes for this item. The forms should more clearly identify what
category these emissions should be reported under. Note this is
equivalent to the first comment on Schedule I, Section 1, question 10,
Scope of Inventory.

**Schedule III:**

Section 1, Table 1 -- There are errors in the entries in the table that
are supposed to help the reader understand where to go for the data
needed in the table. For instance, under Item A1, the reader is directed
to information  in Addendum A1, Item G, Column 2 (A1, G2) when the entry
should be A1, I2. The table contains many similar errors, which need to
be corrected.

**Addendum A1:**

Part A, Output -- The concept of an "indexed measure" is introduced but
is not defined. Nor is such a measure mentioned in either the general or
technical guidelines. Assuming that this is consistent with the general
and technical guidelines, it should be explained.

Part B, question/table 1 -- Again, the table contains incorrect
instructions as to where to go for the data needed to complete the
table.

Part B, question/table 6 -- Since reductions calculated using the
intensity method are (according to the guidelines) presumed NOT to be
associated with reduced output, it is unnecessary for the question to
ask if the reductions were due to plant closing.

**Addendum A2:**

Part A, question 4 -- The question asks whether, for this Entity or
Subentity, the reporter is intending to register reductions on Addendum
AI (the intensity method) as well as on Addendum A2 (the absolute
method). The guidelines indicate, however, that a subentity is to use
only a single method. If multiple methods are needed, additional
subentities should be created. To avoid confusion, the word "Subentity"
should be removed.

**Addendum A3:**

Part A, question/table 1 -- Again, to avoid confusion, it would be
helpful if the table contained a "zero" where an entity is supposed to
enter the stock changes associated with sustainably managed forests.

Part A, question 4 -- It does not appear relevant to ask whether
reductions via carbon sequestration were due to plant closings.

**Addendum A5:**

Part B, question/table 1 -- There is at least one error in the second
column which attempts to direct the reader to the places in other tables
that contain the data needed to do the calculations. The error is in
Item I where the equation should be \[(C -- F) \* B\].

**Addendum A7:**

Part B, Table 1 -- Enter Action Characteristics -- The table requires
the entity to report the mass of waste in place in the landfill in
column 5. However, this information is not necessarily required in order
to estimate emissions and reductions in emissions ([e.g]{.underline}.,
if the entity measures actual methane emissions rather than estimating
emissions from kinetic decay relations). Therefore, entry of the total
mass of waste in the landfill should be optional. Also, note that not
all entities will have this knowledge.

Part B, Item 5 - Enter Mass of Methane Captured (page 67 of
instructions) -- The instructions specify use of a methane global
warming potential (GWP) of 23, which is not consistent with the GWP for
methane (21) recommended by other protocols and reporting guidance from
WRI/WBCSD, IPCC, and others.

> **Attachment B -- Corrections to DOE March 2006 Technical Guidelines**

1.  The first five bulleted items on page 20 of the Technical Guidelines
    (examples of industrial process emissions) are duplicates of items
    listed on the previous page (five of the bulleted examples of
    industrial process emissions are listed twice).

```{=html}
<!-- -->
```
1.  The discussion of inferred measurement of nitrous oxide emissions
    from mobile sources (third paragraph on page 27 of the Technical
    Guidelines) includes the statement that "A 1998 model car emits an
    average of 0.2 kg of nitrous oxide per mile traveled." This is
    incorrect and not consistent with the cited source of the
    information (EPA's Office of Mobile Sources). The EPA source
    actually indicates that nitrous oxide emissions are about 0.02
    g/mile traveled, which is four orders of magnitude lower than the
    emissions suggested in the DOE Technical Guidelines (see Table 1.D.2
    on page 70 of the Technical Guidelines).

2.  Table 1.C.6. (Emission Factors and Other Default Characteristics for
    Distillates and Fuel Oils...) on page 45 of the Technical Guidelines
    contains erroneous CO~2~ emission factors for Middle Distillate Fuel
    and for Kerosene. The listed emission factors for these two fuels,
    presented in units of metric tonnes CO~2~ per 10^9^ HHV Btu, are an
    order of magnitude too high.

3.  On page 47 of the Technical Guidelines, the fourth bulleted item
    incorrectly refers the reader to Table 1.C.11 (the correct table
    reference should be Table 1.C.10.).

4.  Note that Table 1.E.30. (Default COD Values for Various Types of
    Industrial Wastewater) on page 125 of the Technical Guidelines
    contains a default wastewater flow rate of 85 m^3^/metric tonne
    production and a default organic loading value of 0.4 kg BOD/m^3^ of
    wastewater for pulp and paper mills. Based on data NCASI published
    in Technical Bulletin No. 860, the median wastewater flow for
    bleached Kraft pulp and paper mills was about 72 m^3^/metric tonnes.
    Wastewater flow rates would be less for all other pulp and paper
    industry sectors. Therefore, the DOE Technical Guidelines would tend
    to over-estimate aqueous organic wastes from the pulp and paper
    industry manufacturing facilities.

5.  Text discussing transmission and distribution losses corresponding
    to purchased electricity on page 159 of the Technical Guidelines
    refers to Table 1.F.4 for a set of default transmission loss
    factors. However, Table 1.F.4 (on page 153 of the Technical
    Guidelines) presents rating characterizations of methods for
    estimating indirect emissions from electricity imports, not
    transmission loss factors as stated in the text on page 159.

[^1]: 71 Fed. Reg. 42637-42639 (July 27, 2006)

[^2]: World Business Council for Sustainable Development/World Resources
    Institute, "The Greenhouse Gas Protocol -- a corporate accounting
    and reporting standard", page 39.

[^3]: World Resources Institute/World Business Council for Sustainable
    Development (WRI/WBCSD), Greenhouse Gas Protocol, Calculating CO~2~
    emissions from the combustion of standard fuels and from
    electricity/steam purchase -- Guide to calculation worksheets
    (October 2004) v2.1
    (http://www.ghgprotocol.org/DocRoot/dPZVGx6seDqdnWJeod3s/co2-combustion.pdf).

[^4]: US Environmental Protection Agency (EPA), Climate Leaders
    Greenhouse Gas Inventory Protocol Core Module Guidance -- Indirect
    emissions from purchases/sales of electricity and steam (October
    2004)
    (http://www.epa.gov/stateply/docs/indirectelectricityguidance.pdf).

[^5]: International Council of Forest and Paper Associations/National
    Council for Air and Stream Improvement (ICFPA/NCASI), Greenhouse Gas
    Calculation Tools for Pulp and Paper Mills, Report Version 1.1 (July
    2005)
    (http://www.ncasi.org/programs/areas/climate/ghgtools/pulp_icfpa.aspx).