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> November 12, 2023

Mr. Mark D. Friedrichs Reference:

Office of Policy and International Affairs 10 CFR Part 300

U.S. Department of Energy RIN 1901-AB11

1000 Independence Ave., SW

Washington, DC 20585

Dear Mr. Friedrichs,

Global Warming Initiatives agrees with most of the proposed revisions to
the General Guidelines for Voluntary Reporting of Greenhouse Gases with
the following comments for consideration.

**Aggregators:** Another question concerns the possible role of trade
associations and other third parties as consolidators/aggregators of
entity-specific reports into an aggregate report to DOE. While
associations may report information collectively for their memberships
under the current guidelines, this may have implications for the
accuracy and reliability -- and transparency -- of reports submitted
under the revised guidelines. Should trade associations and other third
parties be required to submit some or all of the entity-specific data
that might be required by the revised Guidelines? Should the CEOs, other
senior officials, or heads of entities be required to certify the
accuracy of their companies' reports when submitted to or through trade
associations? Should trade associations and other third parties be able
to "register emission reductions" or only file reports for the record?

Global Warming Initiatives (GWI) is an Aggregator of DOE VRGG industrial
submission within North Carolina. For the last three years, N.C. has led
the nation in the number of facilities reporting. Each of the
corporations are also EPA Energy Star -- Industrial Sector Partners. The
best ways to answer the above questions are to highlight how GWI
performs the role of an aggregator.

-   GWI is a non-profit, 501(c )3 corporation established January 6,2003
    to continue the Climate Wise efforts accomplished since 1995.

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-   Aggregation works fine with 26 companies (40 facilities) being
    served with \$60,000/yr from EPA/DOE being matched by N.C. until
    Climate Wise ended in 2000 and State monies ended June 30, 2002. You
    don't drop a winning program just because the dollars run out.

-   GWI has the initial corporate presentation to the CEO/President,
    CFO, environmental/plant/process engineer and plant manager. The
    federal and state programs that are available as tools to increase
    their assets are presented and if they meet the companies ROI, why
    not do them. The added benefit of reporting the savings in
    greenhouse gas emissions are explained as a win-win program at
    little cost. A contact person that knows the intricacies of the
    corporation/facility is assigned as our working liaison.

-   An action plan is created of past, present, and future projects form
    surveys, site engineers, and maintenance personnel. Additional
    surveys are suggested and incorporated into the action plan.
    Quarterly, GWI contacts the company to see what additional help they
    might need and update the completed projects.

-   The data needed to report to the VRGG is provided by the company and
    GWI enters the values, performs the conversions, prepares an annual
    report, and assesses the data for credibility. Every companies
    report is identical and the format with conversion factors verified
    by VRGG. The completed submission is sent back to the company
    contact for review at the same time it is sent to VRGG for their
    review. If any concerns are found by VRGG they are presented to GWI
    who either answers the concern or obtains the answer from the
    company.

-   The final report and certification letter is presented by a GWI
    engineer to the company contact and senior management for their
    review and approval. The data is not accepted by VRGG until the
    certification letter has been received signed in original ink. This
    report also is sent to Energy Star as their annual report.

-   The GWI employees that work with the companies are Certified Energy
    Managers (CEM) as accredited by the Association of Energy Engineers
    (AEE) that re-certify every three years the competency of their CEM
    personnel.

-   Transparent- all reports are identical, wither 40 reports are right
    or all wrong. If a correction is needed by VRGG then all reports can
    be updated at the same time. The companies can compare their
    emission data with their peers and understand what they are looking
    at. Exchange of best practices is encouraged.

-   GWI participates in DOE, USDA, and EPA workshops and seminars. We
    continue membership in trade associations and federal programs to
    assure a leading edge that we can transfer to the corporations.

-   GWI is also a EPA Waste Wise collaborator, presenting this program
    along with Climate Vision and Climate Leaders to businesses in N.C.

-   The drawbacks:

1.  Climate Wise was free until the pilot program ended and the state
    had no program to match and its funding stopped.

2.  All companies wanted to continue reporting, most promised support
    toward this effort but never came through with the dollars. Many
    were having financial problems, economy bad, closing facilities,
    layoffs, moving manufacturing out of country, and remembered when it
    was free.

3.  Many said they would provide the data but no manpower or dollars.
    All want a free-ride.

4.  Since 1995, the programs have promised some financial consideration
    for participating. Even now with the new program, there is nothing
    to offer for their participation other than a warm fuzzy.

5.  Several companies said they could only get funding if VRGG was
    either federal or state mandated.

The outlook for voluntary participation without incentives is
questionable. In any case, GWI is trying to promote the Global Warming
issues across the state and provide recognition for what we have
accomplished. GWI has published its version of a North Carolina Climate
Change Registry. The second edition will be out soon and can be reviewed
at [www.gwi-nc.org](http://www.gwi-nc.org/).

**Certification/Verification**: The proposed Guidelines would require
that the chief executive officer or other senior official of the
reporting entity certify the accuracy, consistency and completeness of
all reports. In addition, the Guidelines would encourage, but not
require, independent verification of all reports. The proposed
Guidelines would provide only general guidance on what DOE considers the
necessary qualifications of verifiers and the information that they must
verify. This guidance is intended to provide some assurance that such
verifiers are independent and appropriately qualified, while still
giving entities considerable flexibility in the selection of the type of
firm most appropriate to perform such an independent verification.

Independent verification is only necessary if entities seek to sell
their registered emission reductions and, in such cases, private markets
are likely to specify the type of independent verification required.
Requiring a senior officer to certify reports will provide adequate
assurance that the data reported are reliable, the proposed Guidelines
would strongly encourage reporters to obtain independent verification.

. \"Qualified\":

(a) Verifiers must be certified by independent and nationally-recognized
    certification programs for the types of professionals needed to
    determine compliance with DOE\'s reporting Guidelines, such as the
    American Institute of Certified Public Accountants, the American
    National Standards Institute and Registrar Accreditation Board\'s
    (ANSI-RAB\'s) National Accreditation Program, or the Board of
    Environmental, Health, and Safety Auditor Certification (BEAC).

GWI recommends that the Association of Engineers, Certified Energy
Manager (AEE-CEM) credential be listed as one of the independent and
nationally-recognized certification programs. The CEM deals primarily
with the scope of work that is addressed in the revised VRGG program.
The following is a brief description of the CEM program;

As AEE's first and most widely recognized professional certification,
the CEM credential is now used by many corporations as a prerequisite in
job descriptions for energy management related positions. The
requirement for obtaining counsel or services of a CEM is also now
included in a number of government agency specifications. AEE is
interested in working with this program to enhance the training and
credibility of its program to further serve the DOE VRGG. For further
details see; [www.aeecenter.org](http://www.aeecenter.org/).

**[International Emission Reductions]{.underline}**. The proposed
revised Guidelines should address both the reporting and registration of
non-U.S. emissions and emission reductions, recognizing that the current
guidelines provide for reporting of international activities.

-   Many U.S. corporations have non-U.S. facilities as do Non-U.S.
    corporations have facilities in the U.S. With cap and trade already
    existing in part of the world, and potentially in the U.S., there
    should be some sort of reciprocation of registered emissions. The
    best attempt should be made to match the international requirements
    to the revised registration allowing ease in recognizing and
    accepting other nation's emission reduction activities.

-   U.S. corporations would register their U.S. emissions through VRGG
    and separately register their non-U.S. emissions in order to account
    for the U.S. data nationally separate from the international
    activities. Likewise, other countries would do the same in order to
    lessen double counting. The tracking of trading within, between
    corporations, or through a broker should not be part of this
    proposed registry. This proposal should set standards of emission
    reporting, asses the voluntary participation, and tally the results
    achieved within the U.S. boundary. Corporations could sum their
    world-wide emission changes for their own use and public recognition
    if they so desired.

-   To be eligible for registration, non-U.S. emissions reductions would
    be registered separately from the U.S. corporations and require the
    same verification as required herein. If the non-U.S. country had a
    reciprocal agreement, the U.S. should recognize their verification
    methods.

-   There is no reason why these revisions should not recognize and
    attempt of have similar requirements as non-U.S. activities and
    recognize their efforts that parallel the U.S. mission.

-   Global Warming Initiatives is an aggregator of DOE VRGG industrial
    submissions within North Carolina. For the last three years, N.C.
    has led the nation in the number of corporations reporting. Last
    year, one of the worlds largest brokers of greenhouse gases
    approached GWI and wanted to buy all tons of CO~2~e that had been
    submitted to VRGG as a block. The proceeds would have come to GWI
    for distribution to the corporations participating. We elected to
    hold off on this proposal until this new proposal was finalized, we
    didn't want to shoot ourselves in the foot if these emissions could
    be part of the new program. We hope that the new proposal will be of
    sufficient worth to allow consideration for sale prior to and after
    the U.S. implements cap and trade.

**State Registries:** GWI believes that all state registries be similar
to the National Electric Code. The Code is adopted in its entirety and a
few sentences or paragraphs are added to personalize it to the specific
state. Likewise, GWI has published its version of a North Carolina
Climate Change Registry. The second edition will be out soon and can be
reviewed at [www.gwi-nc.org](http://www.gwi-nc.org/). To be a useful
took for a state, this new proposal should;

-   The state should encourage reporting to the VRGG program.

-   DOE should make the VRGG submissions available as soon as they are
    verified and ready to be put in a data base. The last reports for a
    year should be posted by the end of the third quarter in order for a
    state to prepare its report by year end.

-   DOE should make the software it uses for reports available for
    states to modify for use as their reporting mechanism if so desired.

-   The above data should be made available to the public.

> **Conclusion:**
>
> Global Warming Initiatives is honored to be able to submit these ideas
> for consideration in the revisions to the VRGG. Please call if you
> have any questions or if we can serve in any way to improve this
> program.
>
> Sincerely,
>
> James R. Haven, CEM
>
> Executive Director