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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

Subject: **Proposals to the E-VRGG Program**

Dear Mr. Friedrichs,

Global Warming Initiatives (GWI) is a non profit, 501(c)3 corporation
established to continue the efforts of the joint DOE-EPA Climate Wise
Pilot Program that North Carolina joined in 1994. This pilot program
provided the guidance for EPA to create the Energy Star-Industrial
Sector Program and the EPA Climate Leaders Program, along with guidance
to the DOE Voluntary Reporting of Greenhouse Gases Program (1605b).

GWI is currently working with entities in nine states and eight non-US
countries related to E-VRGG reporting. GWI collects emission and
production/economic data by facility, then using the same procedure for
each facility and corporate level (entity) to complete the 1605b
submission. Then review the report with senior management along with the
action plans for the upcoming year. Obtain certification and forward the
report to DOE.

Global Warming Initiatives appreciates this opportunity to submit
comments and agrees with most of the proposed revisions to the Enhanced
General Guidelines and to the Technical Guidelines for Voluntary
Reporting of Greenhouse Gases (E-VRGG) with the following concerns for
consideration.

**General Comments:**

**The Greenhouse Gas Protocol** of the WRI/WBCSD has tools, procedures,
and guidance that should be used in the E-VRGG instead of trying to
develop new tools or change definitions or wording just to be different.
The GHG Protocol is used world wide as the standard and this program
does not need to vary from its basis. The Technical Guidelines should
have incorporated the GHG Protocol by reference then added unique
changes as required in the United States. This same philosophy goes for
the Climate Leaders Design Principals and Core Modules. One set of
manuals for the US should suffice and be compatible with The GHG
Protocol.

**Balance rigor with practicality, stringency with flexibility** was
part of the directions given at the onset of revising the 1605b program
was to. Balance voluntary approach with a goal-focused program and
confidentiality with verifiability to promote credibility. Somewhere
rigor was lost when the when sections like the A-B-C-D rating system was
conceived. This rating system should be deleted. The necessity is not
there and the detriment to increasing participation is high. The various
methods should be included and emphasis on which to use can accomplish
the same goal.

**Definitions (300.2)**

"**Aggregator** means an entity that reports to the 1605b program on
behalf of non-reporting third parties, usually small emitters." First,
remove 'usually small emitters'. Does this mean the aggregator as an
entity could register under its corporate name all of the participating
non-reporting third parties with each of them being considered a
sub-entity having given the aggregator a legal document to so report?

**De minimis emissions**: If we take 3 percent off the emissions each
year it adds up to quite an emission reduction. If you are assuming this
each year, shouldn't we take 3 percent off the base year amount used in
determining the intensity level? What if each entity reported all they
could and estimated their amount of de minimis emissions up to a maximum
of 5 percent? They would indicate their estimated de minimis and post it
on the report then subtract that amount from the base year value used to
calculate intensity in the current years calculations.

**Submission of an entity statement (300.5)**

**A company continuously reporting their early action to the 1605b
program** was the basis for President Bush giving the directive that
they be provided due consideration and recognition with any Federal
program updated or created was lost by fixing registry no earlier than
2002. Don't loose sight of those participants that took early action by
reducing emissions and reporting when our government needed to show
voluntary participation. The E-VRGG slights their actions when they
should be allowing registration to the champion companies that are
leading our Nation. Do away with the 2002 block on prior registration.

**Register by entities, report by facilities. (300.5)**

Many programs require the increases or decreases of greenhouse gases
emissions to evaluate and improve their reduction strategies. This data
is needed at the facility level along with the entity level. The
proposed Climate Stewardship Act, state programs, regional programs,
etc. require summation of reduction activities on a state level. Other
programs require city, county, or regional areas of a state be summed.
These are programs like ICLEI-Cities/Counties for Climate Protection,
regional EPA initiatives, etc. that need greenhouse data by region.
Other Federal programs could review the facility emissions in regions
that their initiatives are working.

To accomplish this, the E-VRGG would require all entities that are
requesting entity wide reporting would report the facilities to allow
regionalization. The states, cities, and regions are going to ask or
require this information from facilities operating in their regions. It
makes sense to have one place to go for this data, the E-VRGG database.
Sorts on any criteria could be performed quickly and with transparency.
Since the data base would be public record, any requestor could perform
the search and prepare whatever reports they so desired.

An entity would provide a list of facilities that made up their registry
request. The individual facilities would be reported with a designation
if the data was also being registered at an entity level. This would
make it easy to separate the reports that were for information only and
those registered.

If reporting by facility is not included, consider the time and costs
for each facility to prepare an individual report without an overseeing
agency to put validity and transparency to the data.

**Eliminate Large and Small designations (300.7)**

An example of streamlining the enhanced version would be to eliminate
the large and small emitter associated with 10,000 metric tons of CO~2~
equivalent. The requirements are so similar that you would automatically
be registered if you fulfilled all the requirements, else you would be a
reporter. We don't need to apply the stigma to a corporation that they
are a small-second hand operation, give them the incentive to grow and
become registered. Give the companies a way to enhance their previous
years and easily transition into a registered status.

**Public Access to Reports (300.13)**

The data and reports created by DOE from the entities submissions along
with the software program and master data file should be made available
to the public, or at least to the states and their agencies or
contractors.

**Trade Associations and E-VRGG**

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?

**International Emission Reductions.**

Since the E-VRGG allows reporting or registering non US emissions of
corporations that have at least one facility in the US, take due notice
of the international reporting programs and make the E-VRGG as close as
possible for ease in data exchange and analysis.

**Third party verification (300.11)**

Independent verification should not be required to register. This
requirement should be between the parties that are trading emissions.
This should not be an expense directed by the registration program.
Qualifications and names of registering agencies should not be a part of
this Program. It could be an information file in the EIA home page. An
entity might have one year of reductions then four years of no
reductions but each year you have to pay for registration whether or not
you intend to trade. The agency purchasing the credits might accept the
entity's certification or the aggregators report as sufficient to
satisfy the purchase leaving all third party verification as an
unnecessary expense that could have been used on reduction projects. It
would be less expensive to obtain third party verification for a block
of years being proposed for trade at time of the trade than one year at
a time. The purchaser may require third party verification only every
two or three years in lieu of spending money for annual inspections.
Another great benefit of the E-VRGG program eliminating the verification
concept is the increase of participation in reporting.

**Acceptance of Reports (300.12)**

The data collected by E-VRGG should be reviewed, corrected, and made
public in less than three months if possible. This way an entity could
track where emphasis should be given by facility to improve their
greenhouse gas emission reductions in a timely manner prior to year end.

Most of the data is the same as the requirements of EPA's Climate
Leaders Program, California Climate Action Registry, RGGI, Chicago
Climate Exchange, states registries, etc. Each program could pull the
largest percentage of their data directly from E-VRGG and convert it to
their formats. Likewise if California, EPA, CCX, had the E-VRGG data in
their database, it could be directly converted to the DOE required
format.

The requirements of the proposed Climate Change Credit Registry should
be integrated into the E-VRGG to allow validity, transparency, check and
balance between each agency. The dotted line between the two agencies
should be a very heavy dotted line. This falls under the suggestion that
ALL individual registry programs nationwide deposit their data in only
one national registry under DOE-EIA VRGG. One place to house all
registry data. This would provide the required hooks to the proposed Cap
& Trade program under the Climate Stewardship Act.

**State Web site linked to the E-VRGG data collection site (300.12)**

The states might have unique data requests that they would like to have
collected at the same time as the E-VRGG data is being entered. This
would be at the end of the main report with a listing of all states
where the entity has facilities, posted earlier, with a link to the
specific site.

**Public Access to Reports (300.13)**

The data and reports created by DOE from the entities submissions along
with the software program and master data file should be made available
to the public, or at least to the states and their agencies or
contractors.

**Conclusion:**

Global Warming Initiatives is honored to be able to submit these
suggestions for consideration in the revisions to the E-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