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

February 11, 2004

Mr. Mark Friedrichs, PI-40

Office of Policy and International Affairs

U.S. Department of Energy, Room 1E190

1000 Independence Ave., S.W.

Washington, D.D. 20585

Submitted by email: <1605bgeneralguidelines.comments@hq.doe.gov>

**Comments on Proposed Changes to General Guidelines for Voluntary
Reporting of [Greenhouse Gases under 1605(b) of the Energy Policy Act of
1992]{.underline}**

The American Forest & Paper Association (AF&PA) appreciates the
opportunity to submit comments on the Department of Energy's (DOE's)
proposed General Guidelines for Voluntary Greenhouse Gas Reporting.[^1]
AF&PA, the trade association and leading voice for the forest products
industry, represents over 200 companies and related associations in the
industry. AF&PA members produce over 80 percent of the wood, paper, and
other forest products manufactured in the United States; our members
include non-industrial private land owners, large multi-product
producers, and family owned mills.

AF&PA members own a large portion of the commercial timberland in the
United States and annually plant nearly half of all the tree seedlings
in the country. Atmospheric carbon dioxide (CO~2~), the raw material for
photosynthesis and tree growth, is stored or sequestered in trees.
Sequestration of CO~2~ continues in the industry's products -- wood,
pulp, paper, and paperboard -- and is maintained throughout the lives of
these products.

The forest products industry grows, harvests, and processes wood and
wood fiber, manufactures wood products, pulp, paper, and paperboard
products from both virgin and recycled fiber and also produces
electricity and some bio-based chemicals. Companies in the industry are
involved in some or all of the above activities. The principal raw
material for the industry is wood, which is a renewable resource and a
greenhouse gas emissions neutral fuel. Greenhouse gas emissions in the
industry primarily result from the use of fossil fuels that supply part
of the energy used to manufacture products from forests.

AF&PA has long been involved and has considerable interest in greenhouse
gas related issues. We are a participant in the Administration's Climate
VISION program. We have previously submitted two set of comments in
response to DOE's May 6, 2002 Notice of Inquiry, have met with the
Administration's representatives on 1605(b) issues, and have
participated in all of the DOE's 1605(b) workshops and at the Department
of Agriculture's (USDA) forestry workshop. Changes in greenhouse gas
emissions reporting proposed in the Federal Register of December 5, 2003
are important to AF&PA and its members, and we hope that our comments
are helpful as the agency evaluates responses to its proposal.

**Overview of Key Comments** -- The greenhouse gas emissions reporting
proposal of December 5, 2003 addresses or asks about many critical
issues of interest to the forest products industry. These include:

-   **The relationship of the general and technical guidelines** -- We
    urge that the proposed General Guidelines be revised based on
    current comments and be re-proposed when the new Technical
    Guidelines are proposed.

-   **The definition of avoided emissions** should be expanded to
    include a variety of activities, including recycling.

-   **The definition of carbon stocks** should be expanded to include
    carbon in forest products.

-   **The definition of entity** should be revised to include trade
    associations.

-   **The definition of emissions** should be redefined to include
    "gross" or direct emissions. Direct and indirect emissions should
    both be reported but should not be added together.

-   **Biomass emissions** from combustion should be recognized as carbon
    neutral and reporting of biomass-derived CO~2~ emissions should be
    optional.

-   **Reductions in Emissions** related to plant closures and shifts of
    production should be fully recognized so long as the emissions
    accounting is transparent.

-   **The calculation of sequestration** should recognize that any
    emissions from a sustainably managed forest are *de minimis.*

Details related to these key points as well as other comments follow.

**[I. General Comments and Responses to Questions in
Preamble]{.underline}**

**Future Technical Guidelines** -- Throughout the proposed General
Guidelines, DOE refers to the future proposal of Technical Guidelines,
which will provide technical information on the calculation of
greenhouse gas emissions and sequestration. While it is possible to make
broad comments on the proposed General Guidelines, better and more
focused comments could be made if both the General Guidelines and the
complete set of Technical Guidelines were available for comment. We
strongly recommend that comments on the General Guidelines be accepted
for consideration through the period when the Technical Guidelines are
proposed for comment. Alternatively, the revised General Guidelines,
which have been revised based on this round of comments, should be
proposed again with the complete set of Technical Guidelines.

Additionally, it appears that the Technical Guidelines are being
developed in two separate government departments; every effort should be
made to assure that the proposals work well together and that all the
Technical Guidelines are proposed at one time for public review and
comment.

**Recognition of Industry Methodologies for Calculating Emissions** --
Greenhouse gas reporting is an international issue, and many industries
have developed specific methodologies for calculating greenhouse gas
emissions. The international pulp and paper industry, acting through the
International Council of Forest and Paper Associations, has developed a
calculation tool for determining greenhouse gas emissions from pulp and
paper mills. The method is industry specific and is an accepted module
under the World Resource Institute/World Business Council for
Sustainable Development's Greenhouse Gas Protocol. A similar tool is
nearing completion for wood products facilities. To be consistent, DOE's
Technical Guidelines should adopt by reference these two calculation
tools. Copies of the calculation tools for pulp and paper mills and wood
products facilities are attached.

**International Issues** (Preamble, pg. 34) -- DOE asks if non-US
emissions and emission reductions should continue to be eligible for
reporting under the revised program. AF&PA recommends that they should.
Many AF&PA members operate internationally and think the US registry
should be compatible with international registries. In particular,
internationally accepted methods for calculating greenhouse gas
emissions, as previously discussed, should be recognized by the
Technical Guidelines.

**Climate VISION (**Preamble, pg. 36) -- DOE asks if the 1605(b) program
should also be used to document progress of participants in the Climate
VISION and other voluntary programs. Trade associations in the Climate
VISION program certainly should have the option of using the 1605(b)
program to record progress, but it should not be the only mechanism for
reporting progress under the Climate VISION program.

**Confidentiality** -- Under existing guidelines, reported data are kept
confidential. DOE should maintain this confidentiality provision. Loss
of confidentiality of reported data is likely to discourage voluntary
participation in the greenhouse gas emissions reporting program.

**[II. Specific Section Comments]{.underline}**

**[Section 300.2 Definitions]{.underline}**

**Avoided Emissions** -- The DOE proposal defines "avoided emissions" as
"the emissions displaced by increases in the generation and sale of
electricity, steam, hot water or chilled water produced from energy
sources that emit fewer greenhouse gases per unit than other competing
sources of these forms of distributed energy." We support recognition of
avoided emissions from the export of electricity or steam under the
proposal. As suppliers of electricity generated from renewable sources
and cogeneration, AF&PA members have great interest in avoided
emissions.

However, the proposed definition is too narrow and should be expanded to
include other activities. AF&PA suggests the following definition be
used:

> Avoided emissions are greenhouse gas emission reductions associated
> with a specific activity or project undertaken by an entity and are
> calculated relative to a reference case (or baseline) that describes
> what the emissions would have been in the absence of the entity's
> activity or project.

For example, recycling of paper, aluminum, and other products reduces
disposal in landfills and may reduce energy usage. The recovery of paper
and wood for recycling avoids product disposal and should be recognized
as an activity that avoids methane emissions at landfills. The details
of calculating avoided emissions should be left to DOE's future
Technical Guidelines, but the General Guidelines must recognize the
climate benefits of avoided emissions, including those associated with
paper and wood recycling.

Also, product substitution should be recognized in the General
Guidelines as potentially avoiding emissions. If wood is used to build
houses instead of brick, steel, or stone, there may be reductions in
greenhouse gas emissions. The life cycle analysis supporting this point
is contained in a 2004 draft report issued by the Consortium for
Research on Renewable Industrial Materials (CORRIM, Inc.).[^2] A copy of
this report is attached to these comments.

AF&PA also has concerns about how avoided emissions are factored into an
entity's emissions reductions. See our comments under section 300.7.

**Carbon Stocks** -- The DOE proposal defines carbon stocks as "the
quantity of carbon stored in biological and physical systems including:
trees, plants and other terrestrial biosphere sinks, soils, oceans,
sedimentary and geological sinks, and the atmosphere." The definition of
carbon stocks should include forest products. A portion of the carbon
that trees remove from the atmosphere remains fixed in wood and paper
products throughout their lives. The harvesting and manufacturing of
forest products essentially transfers carbon from the forests to
products. AF&PA recommends that carbon stocks be defined as:

> the quantity of carbon stored in biological and physical systems
> including: trees, *forest products*, plants and other terrestrial
> biosphere sinks, soils, oceans, sedimentary and geological sinks, and
> the atmosphere.

The U.S. government's national greenhouse gas inventory[^3] recognizes
that the carbon contained in harvested wood products continues to be
sequestered from the atmosphere, and in some cases -- such as building
materials -- products remain in use for very long periods of time. AF&PA
members have reviewed and adopted methods for estimating the amount of
carbon stored in products and want to work with DOE, USDA, and other
interested parties to explain and encourage adoption of these methods
(also see our comments under 300.7).

***De Minimis* Emissions** -- The proposal defines *de minimis*
emissions as the lesser of three percent of an entity's emissions or
10,000 metric tons of CO2 equivalent. Rather than listing a *de minimis*
quantity or percentage, AF&PA recommends that entities be allowed to
list and qualitatively describe *de minimis* areas not included in
reports. A list has several advantages. First, it avoids unnecessary
time and money spent determining a specific *de minimis* amount or
percentage. More importantly, it facilitates certification and
verification of reports. A person certifying a report will have much
greater confidence in the accuracy of the *de minimis* amount if it is
qualitatively stated.

**Greenhouse Gases** -- The proposal defines greenhouse gases to mean
carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O),
hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride
(SF6), and "other gases or particles that have been demonstrated to have
significant, quantifiable climate forcing effects when released to the
atmosphere in significant quantities." AF&PA recommends that "other
gases or particles" be deleted from the list. Emission factors for
converting these gases to CO2 equivalents have not been developed and
agreed upon internationally.

**Indirect Emissions** -- The proposed guidelines define indirect
emissions to mean "greenhouse gas emissions from stationary or mobile
sources outside the organizational boundary of an entity, including but
not limited to the generation of electricity, steam and hot/chilled
water that are the result of an entity's energy use or other
activities." AF&PA members support the inclusion of indirect emissions
in the reporting process but recommend that they be kept separate from
direct emissions to avoid double counting. The pulp and paper mill and
wood products greenhouse gas calculation tools include calculation of
indirect emissions such as those related to the purchase of electricity
or steam, but indirect emissions are listed separately from direct
emissions.

**Net Emissions or Net Entity- Wide Emissions** -- The proposal defines
net emissions as "total, entity-wide emissions, both direct and
indirect, minus entity-wide sequestration." This definition is
problematic, as direct and indirect emissions must be kept separate and
should not be added. To make this clear, we suggest that the term "gross
emissions" be added to the definitions in section 300.2, where gross
emissions are defined as total direct emissions.

Net emissions or net entity-wide emissions are simply annual gross
emissions minus net reductions. For consistency, these *net reductions*
are the same net reductions defined under net entity-wide emissions
reductions (see our comments under 300.7).

**[Section 300.3 Guidance for Defining the Reporting
Entity]{.underline}**

**Entities** -- Currently, the 1605(b) guidelines define a reporting
entity as a "legal U.S. entity," meaning "any U.S. citizen or resident
alien; any company, organization, or group incorporated under or
recognized by U.S. law; or any U.S. Federal, state, or local government
entity." It is important that the guidelines explicitly recognize that
trade associations may report industry sector emissions and reductions.
AF&PA members elected to participate in the Administration's voluntary
climate initiative for industrial sectors, and this commitment is based
on a *collective* effort to try to meet the President's climate goals.
Thus AF&PA members recommend that the 1605(b) registry should be
structured to accommodate reporting of aggregated data by trade
associations.

**[Section 300.5 Submission of an Entity Statement]{.underline}**

**Entity Statements** -- Entity statement requirements under section
300.5 (7)(b) and 300.5 (7)(c) of the General Guidelines demand excessive
detail and discourage entities from reporting. For example, paragraph
300.5(7)(b) would require an entity to report "reasons for changing the
scope of entity reports." Paragraph 300.5(7)(c) would require an entity
to document changes to entity statements in future reports including
changes in the entity's organization (geographic or operational)
boundaries."

Such requirements are overly burdensome. If an entity is following a
well-established protocol, the entity's *certified* emissions and
reductions should be accepted by the 1605 (b) registry without filing an
amended entity statement.

An amended entity statement is unnecessary if rules are established for
making baseline adjustments. With such rules in place, adjustments can
be made to the baseline, and the reporting entity can maintain the
supporting documentation as part of its standard business records. AF&PA
recommends that baselines be adjusted when entities *transfer* or
*acquire* operating facilities or activities. Conversely, actions that
*increase* emissions -- such as an increase in output -- or *decrease*
emissions -- such as closing facilities -- do not require an adjustment
to the baseline.

**[Section 300.6 Emissions Inventories]{.underline}**

**Emissions Related to State or Federal Requirements** -- Section
1605(b) of the Energy Policy Act of 1992 states that the guidelines
shall establish procedures for the voluntary reporting of information on
reductions in greenhouse gas emissions achieved as a result of state or
federal requirements. State or federal requirements can cause either
increases or decreases in emissions. AF&PA recommends that the
guidelines provide for the reporting of both increases and reductions
from such requirements and that such changes be separately tabulated.

Tracking this data will allow lawmakers, reporting entities, and the
public to better assess regulatory requirements that lead to increases
in greenhouse gas emissions. In cases where compliance with new
regulatory requirements cause greenhouse gas emissions to increase,
AF&PA recommends that a system of compensating credits be established.

**Biomass Based Emissions Reporting** \[Sect. 300.6(b)(2)\] -- The
proposed guidelines call for reporting of greenhouse gases from
combustion of biomass fuels under the paragraph labeled "Direct
emissions inventories." Biomass emissions should not be classified or
reported as direct emissions. Emissions from biomass fuels -- which are
climate neutral -- should be listed separately and reporting of these
emissions should be optional.

The Intergovernmental Panel on Climate Change has stated that emissions
from biomass oxidation do not add to atmospheric concentrations of
carbon dioxide.[^4] When biomass fuels are burned, the CO~2~ emitted is
the atmospheric carbon dioxide that was sequestered during growth of the
tree; hence, there is no net contribution to the atmospheric CO~2~
level. The carbon cycle is a closed-loop, and new tree growth keeps
absorbing atmospheric carbon dioxide and maintains the cycle. Any
increases or decreases in the amount of carbon dioxide sequestered by
the forests are accounted for in the comprehensive forest accounting
system. This is the approach generally prescribed for national
inventories by the United Nations Framework Convention on Climate
Change. Most international protocols including that of the IPCC have
adopted the convention set out by the United Nations.

**Sequestration Reporting** \[Sect. 300.6 (d) and (e)\] -- Sustainably
managed forests should be considered carbon balanced and any emissions
associated with their management should be considered *de minimis.*
There are a number of forest certification systems, including the
Sustainable Forestry Initiative®, that contain sustainable forestry
performance standards, which forest landowners can use to certify their
operations. AF&PA recommends that entities have the option of reporting
a default sequestration value of zero for forest lands that are
managed under one of these systems. Participating and operating in
compliance with a sustainable forestry system affirms the neutrality of
any carbon emissions from these forest lands.

Requirements to measure fluctuations in forest carbon stocks on an
annual basis can be both costly and unnecessary. Therefore, AF&PA
recommends that the word "annual" be stricken from subparagraph 300.6
(d) and that it be changed to read:

> Changes in terrestrial carbon stocks should be comprehensively
> assessed on a *periodic basis*...

Decisions about an appropriate measurement timeframe should be left to
the Technical Guidelines.

Additionally, entities should be given the option of establishing carbon
management units or projects ([e.g.]{.underline}, conservation areas,
set aside tracts, extended rotations) on designated portions of their
forest holdings. This would allow forest landowners to modify some
forest areas for maximum carbon accrual while continuing to manage the
remaining tracts on a sustainable basis. Periodic tracking of changes in
stock in the carbon management units can be measured using accepted
computer models or other monitoring devices.

It is important that acceptable methodologies be agree upon for
measuring forest sequestration, and AF&PA members want to work with
USDA, DOE, and others to assist in the final selection of such
methodologies.

**[Section 300.7 Net Entity-Wide Emission Reductions]{.underline}**

**Assessing entity-wide emission reductions** \[Sect 300.7(a)(1)\] --
The proposal would calculate net annual entity-wide emission reductions
based on "a full assessment and sum total of all changes in an entity's
emissions, avoided emissions, and sequestration relative to the entity's
established base year (or base period)." There are several aspects of
this definition that need to be modified.

Avoided emissions are calculated relative to an entity's reference case,
not relative to the "established base year (or base period)." It is
important to calculate avoided emissions relative to a reference case or
baseline that is defined for the specific activity that results in the
avoided emissions.

Additionally, annual increases in harvested wood products (in carbon
stocks) and any offsets that may be acquired or transferred need to be
factored into the calculation.

AF&PA suggests that the wording in section 300.7(a)(1) be changed to
read as follows:

> Net annual entity-wide emission reductions must be based, to the
> maximum extent practicable, on a full assessment and sum total of:
>
> items measured relative to the entity's established base year (or base
> period) including changes in
>
> \(a\) direct emissions,
>
> \(b\) sequestration, and
>
> \(c\) indirect emissions;
>
> plus any reductions in the current year accomplished through
>
> \(d\) additions to carbon stocks in products in-use,[^5]
>
> \(e\) avoided emissions, and
>
> \(f\) acquired offsets.

The details of calculating each reduction should be left to the
Technical Guidelines.

**[Section 300.8 Calculating Emission Reductions]{.underline}**

**Reporting Emissions Intensity** \[Sect. 300.8(a)\] -- The proposed
General Guidelines allow use of emissions intensity reporting so long as
"changes in products have not contributed to changes in emissions
intensity." Changes in products and services are business decisions and
occur with some frequency. So long as the accounting is transparent,
reporting of such changes should be accepted. Many changes to product
manufacturing processes are environmentally beneficial, and penalizing
product changes directly conflicts with well established "Design for
Environment" principles that seek to minimize businesses' environmental
footprint through changes that increase efficiency, reduce energy
requirements, and reduce or eliminate releases to the environment
through reuse and recycling.

**Reporting Actual Emissions** \[Sect. 300.8 (b)(2)\] -- The proposed
General Guidelines would allow entities to report changes in actual
emissions so long as "changes were not achieved as a result of
reductions in its U. S. output, or major shifts in the types of products
or services produced." Closure of facilities and changes in products and
services produced are routine business decisions that occur in a viable
market-based economy; if these activities result in emission reductions,
the reductions should be fully recognized. Retention of this restriction
would unnecessarily penalize businesses that make changes that both
reduce greenhouse gas emissions and improve their ability to compete in
an increasingly global economy.

Additionally, the proposed General Guidelines conflict with the
statutory language of the Energy Policy Act of 1992 with regards to
reporting changes in emissions due to plant or facility closings. The
statutory language calls for the establishment of procedures for the
reporting of "reductions in greenhouse gas emissions achieved as a
result of ...plant or facility closings."

Finally, the World Business Council for Sustainable Development and the
World Resources Institute's Greenhouse Gas Protocol (GHG Protocol)
specifically states that "the base year emissions should not be adjusted
for ...plant closures..."[^6] In other words, according to the GHG
Protocol, emission reductions associated with plant closures should be
counted as reductions. To be consistent with this international
protocol, the General Guidelines should allow for the reporting of
emissions reductions from plant closings.

**Reporting Options** -- Entities should have the choice of reporting in
terms of either actual emissions, emissions intensity, or both so long
as the accounting is transparent.

**[Section 300.9 Reporting and Record Keeping
Requirements]{.underline}**

**Base Year** \[Sect. 300.9 (a) and preamble, pgs. 23-4\] -- The General
Guidelines propose use of a base year no earlier than 2002 or an
averaging period of up to four sequential years ending no earlier than
2002. AF&PA supports having the averaging option available and
appreciates DOE's effort to provide flexibility in this area.

The reporting system should provide for reporting data prior to 2002 to
provide a perspective on earlier changes in climate change emissions.
Specifically, the General Guidelines should provide for a baseline
period of 1987 to 1990 as established under section 1605 (b) of the
Energy Policy Act of 1992, and the criteria for reporting and
registration should be the same for reporting periods in the past and
the future.

As the President noted in his February 2002 policy statement, reforms to
the registry system should address baseline protection. Additionally,
the four Agencies that reviewed the President's objectives concluded
that credit should be given for early action. AF&PA members think that
it is important to protect established baselines and give credit for
early action to establish the integrity and reliability of the registry
and encourage participation. Without recognition and credit, those
entities that acted early to reduce greenhouse gas emissions are
penalized.

The forest products industry over the past thirty years has made
significant strides in replacing fossil fuels with biomass fuels, both
waste wood and spent pulping liquor and in developing cogeneration of
electricity in the industry mills. Even within the realm of fossil fuel
use there has been significant replacement of fuel oil with natural gas,
which has reduced greenhouse gas emission intensity.

**Deletion of Registered Reductions** \[Sect. 300.9 (b) and preamble,
pg. 26\] -- DOE asks if registered reductions should be reduced if
annual reports are not made by an entity. Annual measurement of carbon
stocks can be expensive. Consequently, some entities may be discouraged
from reporting if annual reports are required. DOE should allow reports
to be made periodically, and data for any intervening years should be
accepted.

**[300.10 Certification of Reports]{.underline}**

**Certification of Reports** \[Sect. 300.10(a)\] -- DOE asks if the
Chief Executive Officer (CEO) or person responsible for the reporting
entity's compliance with environmental regulations must certify the
accuracy and consistency of the report. AF&PA strongly recommends that
the certification responsibility should be delegable by the CEO to an
appropriate responsible person; such person may be a corporate officer,
but certainly should be an individual with oversight and knowledge of
climate change emissions reporting.

**[Section 300.11 Independent Verification]{.underline}**

**Independent Verification** \[Sect. 300.11 (a)\] -- The proposed
General Guidelines encourage entities to have annual reports verified by
independent and qualified auditors. Such independent verification of
reported emissions is not necessary in all cases. Companies reporting
the information employ professional engineers and certified public
accountants to verify data. Situations requiring independent
verification, such as verification of transferable credits, should be
left to the more stringent requirements set by the appropriate market
regulator or contractual requirements between parties to the transfer.

**[Section 300.12 Acceptance of Reports and Registration of Entity
Emission Reductions]{.underline}**

**Acceptance of Reports and Registration of Entity Emissions
Reductions** \[Sect. 300.12(a)\] -- DOE provides for review and
acceptance of entity emission reports. AF&PA members recommend that such
review be completed within eighteen months of submission of a report. If
a report is not rejected following a DOE review within 18 months, the
reports and registered reductions should be deemed accepted. In the
event that additional supporting information is requested by DOE, this
should not void the 18 month deadline unless DOE deems the report
unacceptable.

AF&PA members hope that these comments are helpful. If you have
questions or we can assist in any way, please contact me at 202-463-2709
or [Dee_Gavora@afandpa.org](mailto:dee_Gavora@afandpa.org).

Sincerely,

![](media/image2.wmf)

Dee Gavora

Director, Enviromental Policy

American Forest & Paper Association

Attachments:

1.  Calculation Tools for Estimating Greenhouse Gas Emissions from Pulp
    and Paper Mills

2.  Draft Final Calculation Tools for Estimating Greenhouse Gas
    Emissions from Wood Products Manufacturing Facilities

3.  Review Draft Consortium for Research on Renewable Industrial
    Materials (CORRIM) Report

4.  GPCARB^©^ product sequestration calculation method

[^1]: 68 Fed. Reg. 68204 (December 5, 2003)

[^2]: "Life Cycle Environmental Performance of Renewable Building
    Materials in the Context of Residential Building Construction,"
    Consortium for Research on Renewable Industrial Materials (CORRIM,
    Inc), Review Draft, January 29, 2004.

[^3]: "Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2001,"
    April 2003, EPA 430-R-03-004.

[^4]: Intergovernmental Panel on Climate Change (IPCC). 1997. Revised
    1996 IPCC Guidelines for National Greenhouse Gas Inventories:
    Reporting Instructions (Volume 1). IPCC National Greenhouse Gas
    Inventory Program.
    http://www.ipcc-nggip.iges.or.jp/public/gl/invs4.htm (26 Nov. 2001)

    Intergovernmental Panel on Climate Change (IPCC). 1997. Revised 1996
    IPCC Guidelines for National Greenhouse Gas Inventories: Reference
    Manual (Volume 3). IPCC National Greenhouse Gas Inventory Program.
    http://www.ipcc-nggip.iges.or.jp/public/gl/invs6.htm (20 Nov. 2001)

[^5]: Georgia Pacific's spreadsheet -- GPCARB^©^ -- used for calculating
    carbon sequestration in products in-use is attached to these
    comments.

[^6]: World Business Council for Sustainable Development/World Resources
    Institute, "The Greenhouse Gas Protocol -- a corporate accounting
    and reporting standard", page 31.