# ![](media/image1.png){width="2.435416666666667in" height="0.9416666666666667in"}

April 7, 2004

Office of Policy and International Affairs

U.S. Department of Energy

Forrestal Building, Room 1E-190

1000 Independence Avenue, SW

Washington, D.C. 20585

**Re: 1605(b) General Guidelines; Comments**

To Whom It May Concern:

The Reusable Industrial Packaging Association (RIPA) appreciates this
opportunity to comment on the proposed General Guidelines for Voluntary
Greenhouse Gas Reporting under Section 1605(b) of the Energy Policy Act
of 1992. RIPA is a trade association representing businesses located
throughout the U.S., Canada and Mexico. In addition, it is affiliated
with parallel associations throughout the world. Its members are
involved primarily in the reconditioning and remanufacturing of
industrial packagings, including steel, plastic and fiber drums, as well
as intermediate bulk containers.

When industrial packagings are reused, significant amounts of greenhouse
gas emissions are saved or avoided. RIPA strongly supports the idea that
companies that make verifiable reductions in greenhouse gas emissions by
using or reusing industrial packagings should receive full recognition
of those reductions.

Presented below are our comments on specific issues raised in the notice
of proposed rulemaking.

-   **Definitions**

The proposed definition of "indirect emissions" should recognize
affirmative actions taken to alter the supply chain in ways that reduce
or avoid greenhouse gas emissions. For example, credit should be
available if suppliers are required to use fuel efficient vehicles to
deliver products, or purchase industrial containers that have been used
or which are reusable. The amended definition would read as follows
(**[new language]{.underline}**):

> *Indirect emissions* means greenhouse gas emissions from stationary or
> mobile sources outside the organizational boundaries of an
> entity...that are the result of an entity's energy use, **[decisions
> directly affecting supply-chain management]{.underline}**, or other
> activities.

A new definition for "Reusable" should be added. The definition would
describe this term for use by entities whose direct or indirect actions
would result in increased reuse of items of trade, such as packaging,
etc. The definition would read as follows:

> **[*Reusable* means an item of trade, raw material, or production
> input that is capable of being used more than once in its original
> intended form.]{.underline}**

-   **Reporting entity definition**

We believe that aggregation and reporting of greenhouse emission data
through trade associations or other third parties will prove to be
highly beneficial, particularly to small and mid-sized businesses, and
should continue to be authorized. Care should be taken to ensure that
reported data is not double-counted, and that it is verifiable. Entities
that choose to report through a trade association or other group should
be directly responsible for the accuracy of the data submitted.

-   **Emission inventories; indirect emissions, avoided emissions and
    *de minimis* emissions**

RIPA strongly supports the right of an entity to report indirect and
avoided emissions in both the baseline inventory and emission reduction
reports, as long as the reporting entity has, when necessary, obtained
appropriate written authorization from other entities, associations or
groups, to claim such emissions.

Entities that continue using reusable packagings continue avoiding
emissions that would otherwise occur if the entity shifted to new,
single-trip packagings. Credit for this activity should be available to
the entity annually because it represents a "best practices" approach to
packaging management.

RIPA supports the right of an entity not to report *de minimis*
quantities of greenhouse gas emissions, but only if (a) all such sources
combined do not exceed 1% of total entity emissions; and, (b) the entity
identifies each emission source excluded under the *de minimis*
exclusion and provides a brief statement indicating the estimated
emission quantity and the reason the emission has been excluded. If a
simple method for accurately calculating small emission sources exists,
the emission should be reported and not counted within the *de minimis*
exclusion.

If entities are not required to report all known emission sources,
neither the agency nor independent auditors will have the means to
determine if the entity has complied with the *de minimis* exclusion,
the legal standard in 1605(b) regarding "accurate reporting" of GHG
emissions, or the stated goals of reporting all "significant" GHG
emissions developing a "comprehensive inventory" of an entity's total
emissions.

To accomplish these objectives, RIPA suggests the following amendments
to 300.6(e):

> \(c\) *Inventories of indirect emissions associated with purchased
> energy **[and packaging]{.underline}**.* \[1\] To provide a clear
> incentive for the users of electricity, **[packaging]{.underline}**,
> and other forms of purchased energy to reduce demand, the consumption
> of purchased electricity, steam, packagings, and hot or chilled water,
> must be included in a reporting entity's inventory as indirect
> emissions.
>
> \(e\) Treatment of *de minimis* emissions and sequestration. Although
> the goal of the entity-wide reporting Guidelines...or difficult to
> quantify. A reporting entity may exclude particular sources of
> emissions or sequestration if the total quantities excluded represent
> less than ~~3~~ **[1]{.underline}** percent of the total annual CO~2~
> emissions of the entity or less than 10,000 metric tons of CO2
> equivalent, whichever is less. The entity must identify ~~the types
> of~~ **[each of the emissions]{.underline}** excluded and provide a
> short justification as to why an estimate was not included in the
> entity's report. **[If an accepted methodology exists to estimate an
> emission, the entity shall state why the methodology was not
> used.]{.underline}**

-   **Net entity-wide emission reductions**

RIPA strongly supports a requirement that assessments of net entity-wide
emission reductions be based upon a full assessment of all changes in an
entity's emissions, emission offsets and avoided emissions, relative to
the entity's base year. To accomplish this goal, it is important that
entities be required to identify all emissions, even those excluded
under the *de minimus* reporting provisions.

-   **Calculating emission reductions; changes in avoided emissions**

An entity should be allowed to report changes in avoided emissions for
certain specified emissions. The list of such actions should include
changes in the entity's use of reusable packaging. Greater utilization
of such packaging would reduce greenhouse gas emissions, and entities
should be able to claim these benefits.

To accomplish this objective, RIPA suggests the following amendment to
300.8(4):

> A reporting entity may use changes in the avoided emissions associated
> with the sale of electricity, steam, hot water or chilled water
> generated from non-emitting sources, **[or from changes in its
> utilization of reusable packaging]{.underline}**, as a basis for
> determining net emission reductions as long as:

(i)....

-   **Appendix A to Part 300**

Appendix A should be revised to present a case study that explains how
an entity may increase its utilization of reusable industrial packaging
to reduce or avoid greenhouse gas emissions. RIPA would be pleased to
provide a brief summary demonstrating how a company could derive
significant reductions in GHG emissions by shifting from single-trip
packagings to multi-trip (i.e., reusable) packagings.

RIPA appreciates the opportunity to comment on the proposed Guidelines,
and welcomes the opportunity to meet with DOE staff to discuss them in
greater detail.

Sincerely,

![](media/image2.jpeg){width="1.6819444444444445in"
height="0.5826388888888889in"}\
Paul W. Rankin

President