check check one two three four five six seven eight nine ten check check one two three four five six seven eight nine ten one two three four five six seven eight nine ten twenty three eighteen good morning and thank you all for joining us i especially want to students who are here this is the senior class from harrington virginia to i understand welcome to our science and technology subcommittee hearing and we're glad you're all here this is our first they're make yourself a homo fit these kids in so they can see a little bit of this here because it's on a topic that i think is of great importance to their future i'm particularly pleased to be able to chair this subcommittee and excited to be able to work with mr inglis a good friend with whom i've had the privilege of traveling to look at some of the effects of climate change by the way bob my take and you'll hear this a lot in this committee this year is i'm no longer to refer to what we're talking about of climate change because it's actually in my judgment lethal overheating of the planet and acidification of our oceans so you'll hear this a lot from me but climate change sounds nice change change we can believe in just helped elect a president and global warming sounds like a good thing we like to be warm but i hate to be overheated and acidification of the ocean is actually also happening i raise that actually have a sadness that a barely a rocket malfunction  carrying a carbon observing satellite because that satellite to go into the ocean instead of into space earlier this morning was a big setback for a scientifically the other side maybe a satellite know something we don't and it realizes that part of the carbon problem is in the ocean and we need to spend more attention there looking on the bright side of course it'll be worthless to us there but this is an important hearing and it's going to give us an opportunity to examine the quality of the information being collected on the emission of greenhouse gases a number of states have a stablish programs to address climate change lethal overheating and to reduce their greenhouse gas emissions over one hundred thirty nations will meet in copenhagen denmark this coming december this is an incredibly important meeting to negotiate a new agr human to control greenhouse gas emissions members of the u s house of representatives and the senate have stated their intention to develop legislation to regulate greenhouse gases and the environmental protection agency is planning to release a federal register notice soon to establish a mandatory greenhouse gas reporting system however in order to evaluate programs either mandatory or voluntary for controlling greenhouse gases we must be able to track emissions accurately we need an accurate measure of baseline emissions we need to know the emission levels we're starting from and we need a good baseline estimate as a benchmark to determine whether control programs are effective or not in reducing emissions we have experience in technologies to monitor emissions from utilities that we gain through the acid rain program under title for the clean air act however there are many more and at ease that need to be monitored under a greenhouse ocean acidification gas control program and some of these organizations have to  programs to attract emissions or to track emissions accurately if we're going to develop a program to control greenhouse and ocean acidification gas emissions we need to start developing tools that will enable regulated entities to track their emissions using methods that are accurate and that are not overly burdensome we have an excellent panel of witnesses today here to tell us about how this could work all three or all of our with us bring extraordinary expertise i look forward to their testimony into their recommendations on how we can ensure the information on greenhouse and ocean acidification gas emissions provides a reliable measure of the mission source and of the effectiveness of policies we may put in place to control the emissions with that i would recognize my friend and colleague mr inglis for his opening statement thank you mr chairman and first of all let me congratulate you on having the gavel in this committee for those if you don't know dr brian baird is really quite an expert on the topics that he was just speaking about and has taught me and i think it's really that is a great thing to have you in the chair and we look forward to working with you in a collaborative fashion you know i have my view is that compromise is not really what we want that's a zero sum game where somebody has won and somebody else's papered over a loss collaboration is where you draw the strengths from both parties and you figure out how to use those strengths to produce something better than either party acting alone could produce and so that's the spirit that i think that chairman baird brings to this committee and  one that i also want to make evident here and so i'm excited about this first hearing in this in this committee because i'm hoping that the panel mr chairman is going to help with a  an idea that we're working on in my office that i've mentioned to you it has to do with a revenue neutral carbon tax as perhaps a better idea than a cap and trade system t problems with cap and trade one is a massive tax increase second it has the to do the prices of the credits going up and down up and down trade about wall street traders gee i don't think that sounds too good in today's environment but a revenue neutral carbon tax transparent so that we can see what the taxes and is revenue neutral which starts with an equal and offsetting tax reduction the payroll tax means that technology then has a source of funding reduce a payroll tax and impose a price on carbon and now people have money in their pocket to afford the new technology and to drive into the energy market the kind of transformational change that we saw with the internet in the p c what the internet what microsoft and apple did for the internet and the p c i think the revenue neutral carbon tax can do for energy you can make it so that entrepreneurs and inventors get married at a certain point on that line and that transparent carbon tax because they'll be clear price signals as to when they should marry and when they should take out the incumbent technology so the reason this hearing is relevant to that also trying to figure out a way to make that so that it is does not punish american manufacturing and the key to that is perhaps a w t o compliant and we're struggling to get there between but i think we can get there border adjustment so that when products come in from overseas we're happy to have been is just we want to apply the same tax that we've applied domestically to those imported goods and one of the key challenges there is figuring out how do you make that fair adjustment and if you can tell me some scientific way that we can judge the carbon output or i should say carbon input into those products that are being imported then and particularly if it's something mathematical some easy way of doing that of course that easy part may be a little bit difficult but if there were some way to project what is the what is a car n footprint of imported goods and then applied equally to domestically produced goods so then you really are looking at the spirit of w t o compliance and perhaps we can work it into a  technical compliance as well with deputy go rules so i'm excited about this hearing because i'm hoping that you have some insights in to that end and how this monitoring might the measuring devices you're talking about may help us as we try to figure out a way to measure the carbon footprint of produced goods produced and imported here it's a key part of this revenue to carbon tax concept it's also one of the more complicated parts of it because the last thing we want is to have american manufacturing subject to this in say the developing world exempt from it that result simply in the export of american manufacturing capacity and that's why kioto failed ninety six to nothing in the u s senate so we can improve on that if we collaborate in them happy to be next to my friend dr baird here on the committee and hope that we can collaborate and look forward to learning from this panel today mr chairman thank you mr inglis for your comments if there are other members of the committee who want to submit additional opening statements your statements will be added to the record at this point and at this point i'd like to introduce our when this is mr john stevens and is the director of natural resources and environment at the government accountability office is joe gravitar is the vice president for policy at the climate registry lesley wong is the director of greenhouse gas programs at waste management incorporated and mr rob alice is the greenhouse gas program manager at advanced waste management systems incorporated as eyewitnesses no you'll each have five minutes for your spoken testimony a written test one will be included in the record for the hearing and when you've all completed your spoken testimony will begin with questions each member of the panel here will have five minutes to question and we appreciate again your presence here and look forward to your input will start with mr stevenson thank you mr chairman and other members of the subcommittee i'm here today to talk about the importance of developing reliable emissions data for carbon dioxide and other greenhouse gases in other words we must know how many times of such gases are actually be released into the atmosphere by power plants industrial facilities and thousands of other emitting sources and be able to measure the changes in those emissions over time before we had six successfully institute any market based mitigation scheme such as cap and trade or the tax program we just heard about that would create a prize for all six primary greenhouse gases carbon dioxide nitric oxide methane and the three synthetic gases it's important to note that the data needs whether emissions on a facilities specific basis or emissions on a economy wide basis depend on the point at which the program regulates and missions that is whether the prig program attempts to regulate a small number of upstream emitters such as fossil fuel producers and importers or instead a much larger number  downstream matters such as individual industrial facilities for example an upstream program for carbon dioxide would likely regulate fewer than three thousand sources and cover virtually all carbon dioxide emissions from fossil fuels whereas a downstream program would regulate about ten thousand large emitters like power plants and cover only about half of the total carbon emissions and general the challenges in establishing baseline emissions data as well as in monitoring reporting and verifying those emissions over time will increase as the number of regulated entities activities and greenhouse gases increase upstream programs would generally have less complex data requirements than downstream programs the us has economy fuel use data which could be used for an upstream program but this would not be suitable for a facility level emissions data needed for a downstream program us also has facilities specific data for carbon dioxide emissions as you mentioned for coal fired power plants but such data is not available for other greenhouse gases or other industry sectors experiences with existing cap and trade programs demonstrate the criticality of quality emissions data for example the us has since hundred five operated a highly successful cap and trade program to limit emissions of sulfur dioxide not a greenhouse gas but a pollutant it causes acid rain the acid rain program has been successful largely because regulated entities are required to routinely monitor report and verify emissions on the other hand as we reported in november two thousand and eight the european trading scheme has been less successful largely because of a lack of quality emissions data causing an inaccurate allocation of  allowances and the beginning and the price of a tonne of carbon to plummet to zero is important to note that the e u program is attempting to regulate only one greenhouse gas carbon dioxide in only one industry sector the power sector on emissions for other greenhouse gases and sectors such as methane from landfills nitric oxide from agricultural operations is far less refined than that for carbon dioxide determining emissions of these gases will be more challenging due to l historical monitoring and a lack of reliable emissions factors nevertheless comprehensive reliable emissions data for all greenhouse gases and all sectors will be essential for any market based medication scheme whether cap and trade or tax currently being debated in the congress there are some existing emissions in the tories and registration and you'll hear about some today that provides a starting point for understanding the challenges in establishing baselines and tracking emissions over time for example the u environmental protection agency maintains an official us emissions amatory to meet our commitments to the un framework convention on climate change but this inventory uses models to estimate emissions at the national and industry sector level and want would not be suitable for a downstream cap and trade system several private nonprofit efforts also provide data collection services for example the world resources institute greenhouse gas protocol is a widely used international accounting system for quantifying and managing greenhouse gas emissions and its developed accounting and reporting standards that are compatible with most inventory programs in addition the climate registry that registry that you'll hear about next includes standards for emissions monitoring and for reporting those emissions through its website the chicago climate exchange also has an emissions reduction and trading scheme and requires its participants to use specific protocols to establish emissions baselines and track progress towards emissions reduction goals but none of these inventories or registry is at the scope or complexity contemplated for a nation wide program in conclusion mr chairman we believe this hearing highlights a critical element of the climate change debate the need to develop high quality emissions baselines for all greenhouse gases and all sectors and the ability to monitor report and verify future missions against those baselines thank you mr chairman that concludes my statement all happy to be happy to answer questions at the appropriate time good morning chairman baird and distinguished members of the subcommittee thank you for the opportunity to testify before you today as an organization committed to the accurate and transparent reporting and verification of greenhouse gas emissions the climate registry is please to brief the subcommittee on these important topics first of like to provide a bit of background on the climate registry the registry is a nonprofit organization created in a collaborative effort by north american states provinces territories and native sovereign nations the registry is governed by a unique board of directors which today consists of representatives from forty one u s states and the district of columbia twelve canadian provinces and territories six mexican states and four native sovereign nations in the map that's projected before you the participating jurisdictions are highlighted in green the concept of the registry took shape as states became increasingly interested in taking progressive action on climate change they realized the opportunity to collaborate with one another to create a unified north american greenhouse gas registry as a result the registry's mission is  consistent and transparent standards to calculate verify and publicly report greenhouse gas emissions and to a single north american registry the registry supports both voluntary and mandatory greenhouse gas programs and provides comprehensive data to promote the reduction of greenhouse gas emissions to date the registry has more than three hundred twenty members representing large fortune five hundred companies electric utilities unisa polities colleges and universities government agencies and small businesses the registr voluntary greenhouse gas reporting program is a ridge or rigorous initiative that requires its members to report their corporate wide emissions of all six kioto gases from their operations throughout north america annually at the facility level this program is based on t important international greenhouse gas accounting standards namely the world resources institute world business council for sustainable development greenhouse gas protocol and the international standard for greenhouse gas accounting i s o fourteen thousand and sixty four part one these standards are compatible and complementary and have become the foundation for greenhouse gas accounting globally the registry's general reporting protocol or g r p builds upon these standards and provide specific direction on how to assemble greenhouse gas inventories answers common questions such as how do i report least vehicles who reports of multiple foot there are multiple owners of a facility and how do i treat acquisition it is important to know the greenhouse gas reporting is substantially different from reporting criteria pollutants which typically can be measured from smokestacks since greenhouse gas emissions are ubiquitous and come from both large and small sources one of the most important aspects of the registries voluntary program is its requirement of annual third party verification verification is a systematic independent and documented process for evaluating the admissions of report against agreed upon criteria but verification is similar to an audit of financial statements it is an extra allowed to station to the quality and accuracy of the reported from ation and it creates confidence in the data that is back at the data is accurate the registry's verification accreditation programs are also based on international standards and are explained in more detail in my written testimony thus far my testimony is focused on the registries voluntary program however the registry supports both voluntary and mandatory greenhouse gas reporting programs many of the states and provinces comprising the registry's board of directors have adopted or in the process of adopting mandatory greenhouse gas initiatives either individually or as part of regional initiatives the registry is currently working with over twenty jurisdictions including the states and provinces participating in the western climate initiative and the midwestern greenhouse gas reduction accord to develop a common greenhouse gas data collection platform to serve mandatory programs across north america at the federal level the registry's board of directors recently adopted a policy statement to articulate the role it seeks for the registry within a federal greenhouse gas reporting program this statement is also included in my written testimony in their statement the board of directors expressed their desire for the registry to be to be viewed as a model and a resource just support federal greenhouse gas registries the subcommittee asked me to speak on the challenges and opportunities associated with tracking greenhouse gas emissions accurately before i do i want to stress the fact that it is indeed possible for most organizations to accurately count for report and verify their emissions today that said there are report there are challenges to reporting and they tend to fall into categories organizational challenges  scientific uncertainty organizational challenges generally occur due to a lack of management systems specifically designed for greenhouse gas data collection since greenhouse gases have not been regulated before many organizations do not have systems in place to monitor and  emissions scientific uncertainty presents additional challenges to obtaining high quality data tell quantification methods for certain sources of emissions either do not exist or contain high degrees of uncertainty by written testimonies describe specific areas of scientific uncertainty the most notable of which is the quantification of fugitive emissions of methane in terms of opportunities to improve the accuracy in greenhouse gas reporting our recommendations include updating emission factors and quantification methods in a timely fashion developing industry specific protocols and improving measurement technologies to conclude the registry was created to help organizations answer the very question posed by this hearing today how do we know it we're emitting given the recent leadership of individual states and regions the u s is well positioned to think about emissions beyond the traditional smokestack approach and to work across state and federal jurisdictional lines to begin to tackle climate change in a new and collaborative way and the registry is uniquely positioned to help we look forward to partnering with the federal government to serve a larger role in supporting national a north american greenhouse gas initiative thank you again for the opportunity to testify and i'd be happy to answer any questions you have chairman baird ranking member anglos and members of the subcommittee thank you for the opportunity to speak with you today about waste management screen house gas program's waste management is the leading provider of waste management recycling and environmental services in north america we also produce renewable waste based energy and up now to power over one million homes a year waste management has chosen to voluntarily participate in greenhouse gas inventory in reduction efforts since two thousand and four both to achieve our own sustainability goals and to help our customers achieve their goals it's important to note however that the way sector is a very small contributor to us greenhouse gas emissions it's less than three percent and through advancing technology environmental regulation and recycling we have decreased greenhouse gas emissions by more than seventy five percent in the past decade despite a two fold increase and waste generation during that time period in addition e p a s two thousand and eight greenhouse gas inventory found that landfill methane emissions have decreased by more than sixteen percent since nine hundred ninety we're a big organization to inventory we have about twenty five hundred sites in forty eight u s states and canada we have recycling facilities transfer stations clean energy power plants hauling companies with over twenty two thousand vehicles and about three hundred active and close to landfills our primary greenhouse gas emissions include direct carbon dioxide from using fossil fuel in vehicles and facilities direct carbon dioxide emissions from the non biogenic portion of the waste combusted in our waste to energy plant in carbon dioxide emissions from landfills this includes fugitive and combustion emissions from landfill gas which is itself approximately a half carbon dioxide and half methane we are already working to to complement our greenhouse gas reduction efforts we have participated in two voluntary greenhouse gas management programs and we're now undertaking a voluntary greenhouse gas footprint of our own development waste management is a founding member of the chicago climate exchange and was the first solid waste company to join since two thousand and four were on track to meet our membership commitment of a six percent reduction from r c c ex baseline by and ten as a c c ex member we prepare a third party verified annual inventory of carbon dioxide from fuel combustion and from waste at our wholly owned waste to energy facilities then in two thousand and six waste management was the first solid waste company to join the california climate action registry known as c car we report direct carbon dioxide emissions from fuel consumption indirect carbon dioxide emissions from electricity use and these are also third party verified reports we also opted to report greenhouse gas emissions from landfills to pilot a landfill greenhouse gas inventory tool called the solid waste industry for climate solutions earth's wix protocol the protocol greatly enhances currently available gas generation models that rely on the fall values by replacing that with measured data this protocol also recognizes carbon sequestration where the anaerobic conditions of a modern landfill allow significant amounts  management carbon footprint project team has so far identified all of our sources identified or developed a mission calculation protocols and developed a software tool for collecting verifiable data from the field the next step i data collection and then comes actual reporting our data will be audited all to support third party verification but we have recommended to e p a that third party verification is necessary in a mandatory climate registry in conjunction with the car but to calculate landfill emissions we will use our swix protocol because it reflects the most sophisticated means of landfall assessment currently available through peer reviewed science however estimation of fugitive landfill emissions is still a work in progress a broadly accepted protocol does not exist however waste management with other industry and academic leaders and a is now conducting tests to measure landfill gas emissions under a variety of conditions and this is detailed in our written testimony we have urged the agency to consider waiting until the results of this research learned that developing a proper program takes significant time we believe a phased approach that allows reporting for a limited range of greenhouse gases or a limited set of sources for the first two to three years is essential we recommend that a federal reporting program provide a transition period and exclude sources for which there is not an approved emission calculation protocol until such time that one is adopted thank you for the opportunity to present this information and i'll be ready to answer questions when you are thanks thank you jim baird and members of the subcommittee appreciate the opportunity to speak on this topic with greenhouse gas offset programs trading in markets such as this ca go climate exchange and with companies publicly reporting their greenhouse gas emissions inventories and programs such as a climate registry the consequences of air and opportunity for fraud are high the protection against this is the requirement that disinterested third parties such as advanced waste management systems or a w m s provide a verification that the reported values are accurate and complete iso fourteen zero sixty four part three and iso fourteen zero sixty five international organization for standardization standards for the accepted rules for conducting greenhouse gas verifications in the us and the world these are the standards utilized for obtaining accreditation to perform verifications friend to do such as the climate registry and the chicago climate exchange both of these organizations of task the american national standards institute and see with accreditation of these verifiers using these iso standards in the protocols of the specific program and she conducts a thorough audit of the verifier to ensure appropriate technical knowledge auditing skills knowledge of the appropriate protocols and implementation of the management system capable of providing consistent work product this accreditation process entails both witnessing of actual verification work and of the verifiers management structure a w m s successfully completed the accreditation process and is now one of six companies accredited to perform verification for the climate registry were also credited to perform verifications for the chicago climate exchange the process for performing greenhouse gas verification vary slightly depending on the program but the need for certainty of the reported that is so great than any greenhouse gas ver rigorous fashion the verification process essentially is a complete deconstruction of a company's inventory data the initial data now this is performed remotely using supplied information such as internal tracking spreadsheets monitoring reports fuel usage receipts etc the verifier uses this hard data to ensure appropriate application of emissions factors and usage of correct equations when generating the inventory or offset amounts along with this more technical analysis comes simple analysis such as looking for transcription errors data entry errors things like that they completed that analysis serves as the basis for a risk assessment approach for onsite activities those areas of the company's inventory judged to be a greatest risk of their material impacted inventory or scheduled for detailed analysis by an on site verification team on site data or on site activities focused on where the data originated examples include verification of monitoring equipment maintenance and calibration verification that all emissions points are included in the inventory and interviews with those responsible for collecting that data the final step in the verification process is a technical review by another verify or from a with within the verification body this is an additional complete verification with the exception being that the observations of the on site verification team are used rather than adding additional onsite burden to conclude i would like to emphasize the importance of the conflict of interest component to any verification program the inherent risk of performing verification of consulting work that one's own company is conducted presents a conflict of interest that jeopardizes any greenhouse gas inventory or offset program such programs must protect against verification bodies hiding consulting work behind false or weak corporate separations additionally relationships in which one verify verify is another's consulting work if the favors return must be watched for advanced waste management systems for example performs no consulting activity of any kind thank you very much and i look forward to answering any questions i thank all the witnesses very informative testimony one of the things that strikes me about this process is it is extraordinarily complex and and my own perspectives i think similar to what mr inglis is alluded to earlier it seems to me on the  terms of the mass production it might just be easier to go upstream and say well let's just tax a ton of coal or a barrel of oil and figure well somewhere downstream we're taking care of that taking care of th o two output from that but at the same time i think the testimony we've heard from waste management from the gravitar suggest that there is a need particular if you look at things like methane sources from agriculture and other things that are not so easily captured upfront i wonder if you could share with us t sort of pros and cons of the upstream versus downstream analysis and monitoring and also carbon versus other non c o two greenhouse gas emissions you directing that and you know we're just old now i would say you're right much more is known about carbon emissions right now than probably any other greenhouse gases and you and because of the acid rain program you do have in stock in the stack monitoring for you know about fifty percent of the meeting sources of carbon dioxide that's not true methane probably methane capture from landfills and so  forth that's probably not as much known but there's a lot of progress as we've heard of working on factors and so forth to estimate those nitric oxide is is even more difficult to estimate because it comes from farming in telling soil and  how are you going to assign a nation's baseline to farms and how are you going to monitor that so and in general i think upstream to easier just because as a number of entities the further upstream you go is the easier it is because of that because of quantities the easier it is to regulate and it is a math problem is congressman baird said to estimate how much a ton of anthracite coal for example would would would result in a ton of missions carbon so a lot of that can be done and can be estimated at that that high level so let's hear from some of our other witnesses about this issue i think is a very interesting observation while the goal for greenhouse gas emissions is for reductions there are different perspectives if you're talking about a downstream corporate wide inventory versus an upstream inventory and i think that that from the climate registry really understood the benefit of having that corporate footprint it gives a company as an opportunity to manage manage their emissions because as we like to say you can't manage what you don't measure and so if you don't have a clear understanding of your own corporate footprint it's difficult to make those reductions while it may be easier to regulate upstream there is still value in having a corporate inventory and many of our companies have benefited from that not only for reducing their own emissions but also for understanding policies for that the federal government might take on in the future as well you could say that my business is the ultimate end of the stream for for many products but what i would like to add to this statement is that lifecycle assessment is extremely important what we need to do is determine the lifecycle carbon emissions of a whole host of products and services and start thinking about who needs to do the inventory who needs to do the reduction you have to have a place to start and that's the life cycle and tori point is valid any comment on this sure i would just like to add that i think the downstream program encourages forward thinking for example the founding reporters to the climate registry a very forward thinking they're taking ownership of their inventory and oftentimes by the time they've called upon us as a verifier and we get there they have already acted to reduce that footprint and reduce that inventory and i think that that's something that's important to keep in mind when you talk about downstream reporting at the entity level as we look towards copenhagen my one of my problems with this approach is i see the urgency is much greater than the bureaucracy's pace and and my fear is as as i listen all the good work that's been done that's encouraging my belief is we have a set of three fifty parts per million of kyoto or at copenhagen and we're already above that and that means dramatic reductions worldwide particularly in our own country and my fear to be honest is that we will spend a lot of time because of the complexities of this issue not agreeing on monitoring and thereby not reducing carbon but if you had to estimate what do you think the likelihood is that we could the something coming out of copenhagen could say well ok we're going to agree on this mechanism and this is how we'll monitor it what i think the likelihood is that we get to that agreement and maybe that's not going to be the goal of copenhagen but at some point if you're going to reduce you're going to have to have some kind of monitoring what do you asking whether we'll reach an agreement on that or whether it's not that i'm you know if you were to say if you were let me say it this way if you were to get some of the top experts yourselves and some other folks in the room and say look we have to come up with a monitoring system in order whether or not we establish ca trade but just to just set aside the cap and trade side set aside a carbon tax just an agreed upon monitoring system and set aside copenhagen just you all get together with some other experts from around the world what do you think it would take us to get get to an agreed upon system for carbon or for all or all screen house gases or parse it out if you want it's probably possible and yes emitting techniques for carbon are better than the other greenhouse gases so it's it's probably possible to i think there's a lot of work to be done on just estimating techniques the metrics that you use and everything else to be able to reliably estimate a baseline nationwide and to be very difficult and time consuming  my sense is that we will come out of copenhagen with a with at least a rigorous agreements and i think if we take the opportunity to look at something like the climate registry which wherein companies are actually reporting their greenhouse gas emissions and the majority of those emissions say from stationary combustion to mobile combustion are in fact easily quantifiable and verifiable there are certainly some accuracy issues associated with some of the other kyoto gases but i think the first step is saying let's do this and and try to do it and perhaps give some flexibility on some of those gases where there aren't as much there isn't as much accuracy out there but at least learn from our that process and evaluate that over time to see where really the scientific net accuracy is needed and how we can focus in on those areas to have a greater confidence in those additional gases but i do think that we should we should and we need to take that step forward and many of the missions are able to be quantified and measured at this point it's encouraging up my time's exp i'd like to ask an open in question but i think my question is coming for enough out of left field that i need to scrap it a little bit again is what i'm looking for is your expertise on monitoring systems and figuring out what body of knowledge out there that might be applied to answering this question if you in a religious sort of ways and means question but if you want to be in compliance with the b t o you to figure out a way to not discriminate against imported goods but at the same time we don't want them to get a freebie in the air so what we want to potentially do is if you do this carbon tax revenue neutral carbon tax you can imply it within the domestic market and that can be removed as a value added tax can be removed when it hits interstate international commerce so you apply it domestically and you can remove it at the border when you're shipping out of course when it gets to another country they can apply it there and so we would like to do is say goods coming in it's subject to the exact same regime that we've got but figure out how to somehow take a shot at the measurement of what it is we go with an upstream application of the revenue neutral carbon taxes seems most reasonable administratively in this country the question is how could you compare that to what ch scribing footprint might be in the materials that are being imported one possibility is to say that here is the average carbon content in american steel and that would be determined by figuring out the all the inputs into that steel and then apply the same tax to imported steel now in some countries that would be in france they might want an adjustment because they say listen we've got a lot of nuclear we would like to  for a lower assessment in china it's basically giving them a free because they're using dirtier technology and dirtier coal right but you have any ideas about how to how to help me out with that measuring so that you can have a inefficient streamlined process of applying applying a domestic standard to internationally produced goods countries but to have a base data collection effort and what different types of manufacturing activities that have them agreed upon at the international level and be able to apply them to products for example if you use nuclear based energy to produce a product it's going to have a lower carbon footprint than a high sulfur coal with no  a huge undertaking and it would have to be agreed upon on an international basis in order to be applied internationally but if the different countries could come together and agree to certain footprints for certain  they could be applied to a manufacturing process to come up with a lifecycle that i would just say that let's let's take to imports from china determining their carbon footprint and what kinds of inventory estimating atec techniques they use  and having to verify and monitor that is going to be very problematic i don't know whether you could estimate that's estimate the carbon footprint for a for like u s product maybe and apply that to the import is exactly what we're thinking when you and i would be much easier at the commodity level like like the example you gave on steel than it would at the the end product level i would think so you know what we're looking for really is some mathematical system yes you can sort of take it all kind of product wouldn't be wouldn't be exact but it would be somewhere in the ballpark and it's important not be discriminatory it can't hurt imports more than it is applied to domestic produce goods  right now e p a is the one that estimates emissions inventories for kioto so for the for the framework convention i should say so they have a probably a jump start on other agencies but a department of energy also has a lot of information on  estimating techniques and what i've been asking about here do you think that's still within the it's that's where it's logical or somewhere else probably i don't know i'd have to think about that  doesn't doesn't seem like he pays a fit for that right chairman thank you very much and first and foremost thank you for holding this hearing this is a very important issue as we look at what's happening around the country but around the world especially as we move forward to continue to create the jobs that we need to be able to get the country moving in the right direction to be able to be smarter about the way that we're developing technologies and moving industry forward but also in the way that we're going to be generating electricity power looking to power our vehicles in this country and the amount of waste mr chairman we know we recently had a hearing on the importance of recycling waste when it comes to technology with computers cell phones and what we need to be looking at and how we're going to evaluate how we can move forward into the future not only are we going to be able to monitor the amount of greenhouse gases mr chairman that are moving forward but we're a coronation perspective how will the climate registry be able to coordinate with the e p a in the states those states that have moved forward i'm proud to say mr chairman i'm actually one of the first dates to adopt a mandatory greenhouse gas reporting program and so how do you envision  that coordination anyone that may want to take that risk thank you very much for the question it's an important one and the climate registry has been interacting with us e p a i has been in conversations with them they are certainly aware of our protocols the work that we've done while we haven't seen the mandatory rule yet that they are about to release on greenhouse gas emissions we hope that it will contain much  derived from much of the information that we've worked on so far in our written testimony we do have a statement from our board of directors that stipulates that at a minimum every federal greenhouse gas reporting program should utilize the greenhouse gas calculation and accounting methods that are consistent with the climate registry allows states and provinces to collect data for federal programs and maintain the state's abilities to collect additional information if they if they'd like so we feel that there's a lot of opportunity for collaboration both on the policy side and also from a data collection standpoint the registry has a number of sophisticated programs that we what we feel would be useful to implementing some type of a federal greenhouse gas registry was you germany or anyone else just chime in on the verification side of things in point two the work that and see is done to coordinate that side of the house and ensure that there consistency and verification activities and the easy example to point to is the i s o fourteen zero sixty five and iso fourteen zero sixty four s three that are internationally recognized standards for performing verification and so as a verifier having gone through the answer you created a sham process we're confident that we can operate on an international scale and programs such as the climate registry in the chicago climate exchange both point to that and see accreditation process as being a requirement so on the verification side i can percent of their total inventory is it possible that some entity could calculate big greenhouse gas gas reductions under the five percent rule without actually achieving the greenhouse gas reductions they're simplified techniques i suppose it's possible that they could wedge something in to that five percent but i think it's unlikely does these tend to fall out to things like you know the chairman's vehicle that he didn't keep good fuel receipts on or something like that that they they can't really wrap their hands around but they need to acknowledge it's there and i think you're unlikely to see large scale program revolving around the sales departments company vehicle or something along those lines so i would say it's very unlikely and mr chairman lastly what i would just like to encourage is that we do reach out to the public utility commissioners around the country can tell you as a former public utility commissioner the work that's being done especially my familiarity with this  dr martin thank you very much isn't it true that water vapor is far and away the largest greenhouse gas i think that is true and if that's true then if the initiative other greenhouse gases increases the temperature of the earth should not have more water vapor which would then start a self and forcing cycle more water vapor warmer earth more water vapor warmer earth if this is true then shouldn't we be in a position to measure globally water vapor so that we could see if this vicious cycle was starting there any focus on that at all but it would seem a priority to their water vapor is the largest greenhouse gas and i think it is if the other greenhouse gases increase global temperature that would mean two would be more water vapor which would mean more global warming so this should start obviously we're in balance now and have been for a long time and if we tipped that balance might not some pretty evil things happen methane is what twenty times more effective than c o two as a greenhouse gas what is the do we know the total contribution of those two presently to as greenhouse gases mass less methane but twenty times more effective well which is the largest contributor now well right now methane's about six percent of the total greenhouse gas but if you apply to a factor that you're talking about we haven't done the math that you could do that and that in other words you know one ton of methane it's probably worth twenty one tons of carbon and it gets even higher for nitric oxide which is three hundred times more potent than carbon dioxide a whole lot less of it now we're focusing right on on landfills for methane but my understanding is that the cattle on the earth may produce more methane may produce more effective global warming than all the cars in all the world now if that's true why shouldn't we have a focus on having less animals we'd be healthier by the way the the meat people bribed the nutritionists to lie about food groups and we now have a meat food group and a dairy food rupe and they are not different as a matter of fact the best proteins in all  world come from the dairy group milk protein is a best protein in the world egg so the second best you assign a value of one hundred to milk eggs or about ninety six and they started to low ninety's and go on down so why shouldn't we have focus we're really worried about global warming why should we have a focus on having less animals that would mean more vegetarians and longer life for all of us i guess it has to be implementable and the certainly the poet hasn't shown his desire to give up meat well i think that that education is a big part of this american people need to know that the proteins they get from dairy products are far superior to the proteins they get from the eight and they need to know it's a protein produced by dairy products require about one hands to one twentieth of the amount of feed that it requires to two to produce meat pork and chicken people brag that they get three pounds of pig for one pound of food that's three pounds of wet pig thousand pounds of milk in a year a ton of dry matter in a year with little more feed than the steer would eat by the way and at the end of the year you still got the cow to eat if you want so if we're really concerned about global warming why shouldn't we be focusing on methane you know if people of most people can vegetarians make a far greater contribution to reducing greenhouse grasses greenhouse gases and every one of us driving a prius isn't that true i suppose we should strive to reduce all forms of greenhouse gas now this one is particular important because knowing you are you reducing greenhouse gases you're improving your health so why shouldn't there be a focus on that i can answer that you're the policy and then you have an obligation program which you all could contribute to in informing american people you don't have to eat meat to get protein when you eat meat you are really contributing to greenhouse warming because methane is twenty times more potent than c o two and data on that maybe not at this point we have not looked at methane emissions from from animals that said i do know that the california climate action registry does have a methane  they're working on methane digesters which in part is capturing some of the emission from animals as emission reduction projects so there has been some work that's been done on this otherwise i'd say that i do think overall the public opinion is beginning to become interested in eating locally if you will to reduce the transportation associated and emissions associated with transporting full food and emissions that result from that so i do think that there is an increasing awareness of greenhouse gas emissions overall wong and then anyone else who wants to to also chime in here what what are the differences between the a chicago climate exchange and the climate registry protocol i just want to get a handle on that for myself the difference is in those protocols that's a good question to begin with the chicago climate exchange is an actual trading system it's a cap and trade system that enforces reductions on its members of course membership is voluntary and the credits that are generated  system can be traded among members but the the other one that you ask about was not the climate registry but the california congress through the climate registry is a set a protocol it is not they do not have their own carbon credits or trading process it's a means of developing an inventory it's a collection of protocols calculation and scientific information guidelines they publish some guidelines for data collection also they are very different one is an organization in and of itself the what you're trading yes sir they do have their own protocols as well and sometimes they borrow from other stablish protocols i think the chicago climate exchange uses the world resource institute protocols might be the baseline but we have a climate registry expert right next to me one of the main differences is that the chicago climate exchange is focused on emission reduction projects so you're taking a baseline and then you're measuring the activity in addition to that baseline in order to quantify an emission reduction the climate registry converse lee is talking about putting together a corporate inventory so that's the primary difference between the two activities one is emission reductions that are then traded on the market and the other is it is a corporate wide inventory that i think went out to from the verification side this cargo climate exchange is a bit more prescriptive in the things that we need to look for for example quarterly monitoring as opposed to just routine monitoring that sort of thing for methane content in the landfill sector for example so there's a bit of a difference in the verification side of thing which is natural since you're talking about dollars a different you know the baseline there and are you talking about reductions with the a c s x is what the interest is but if you compare the climate registry and the measurements there and the measurements different things so it's difficult to do a parallel comparison in some regard also the chicago climate exchange is a private operation whereas california climate action i'm sorry the climate registry is a public endeavor so all of our protocols are vetted publicly with public comment periods and the chicago climate exchange developed their protocols without that public feedback so there is still a private and public difference between the two as well so i do it do we not know what exactly the climb exchange what their other measurements are well i will say that the chicago climate exchange is the protocols are only available to those who participate so they are not available for public consumption for us to do that assessment but right now the baseline este many techniques are not the same and that's that's the point that you're making i think that they need to be standardized for a nationwide system before co work and there are lots of different slightly different estimating techniques for protocols that you can use for various greenhouse gases and i think all of this might just one small correction chicago climate exchange has posted their protocols on their website now they were not available sometime ago but they have i have about it to their website and if i may say if you're looking to the underlying science how do you calculate emissions from a tip typical process they're going to be very very similar they just use the data in different ways thank you in yesterday and they explained they had some frustration that and i'm not sure that's correct but they felt that lead sort of the cation on environmentally friendly businesses i was so focused on the sort of the r value if you will of the insulating value that it didn't look at lifestyle so that would framed buildings could be related could be rated lower according to them than steel or concrete which strikes me in terms of my understanding of life cycle  occasion gas profile would building as a carbon sink whereas burns a lot of fuel to make steel or concrete the reason i asked that is are we had a point and what would it take to get to a point where where i as a consumer who cares about the environment whether it's through my dietary habits or decisions about cars or drinking water out of a bottle to where i could make an informed decision i can look on this you know it's just water but you can look at a bottle and say ok you've got you know x amount of vitamin b x amount of corn syrup whatever but i can't do anything like that easily to to inform myself about the the the  lifecycle carbon footprint are we where we could do that where we could you could have a label that tells you the lifecycle carbon footprint and not just on a product you buy but on the behavior you engage in if i could speak to that briefly a lot of our activities that we've engaged in for sustainability purposes and greenhouse gas management purposes have been driven by our customers our customers have asked for it and we have done the necessary research to supply them with the information they needed either to conduct an activity or to measure the services we were providing for them so yes if there were a system available where life cycle analyses were available it would be very helpful and it's occurring now there is more information out there than you might think fortunately it's hidden in the individual companies web saw it's not been compiled i believe the carbon trust in the u k has began a program where they actually have a kind of a black footprint that is small or large as an indication of the emissions associated with producing that product so i believe that we're starting to get to the point where consumer knowledge and consumer awareness is growing and is interested in terms of the lifestyle i'm not sure how that's going to  climate registry is considering taking on some of these issues of life cycle assessment within our voluntary registry and we'll take all of your remarks into consideration one of the things that strikes me is and you know this better than i but if you were to make an presumption that the there's no that sort of the mortality or philosophical basis there's no reason that one person on planet earth should be able to produce more greenhouse and ocean acidification gases dramatically reduce and and you know back to dr bartlett's observation i think there's a general sense that people feel like well we're entitled to a certain lifestyle and i think gentleman mr stevens said you know people don't want to give up eating meat you know part of acting as a responsible person on a put in a shared environment is you don't say what do i want to do you say what is the right thing to do what are the consequences of my action and the reason i ask these questions is how do we get to that thing even though they knew something else to be true because was in their incentive to do so as we look at the grand scheme of things and as mr inglis pointed out we look at these fluctuations in the markets already in europe how do you get around that  if you come up with a complex cap and trade kind of system how do we prevent it from market manipulation dishonest numbers etc well i think the simple answer is third party  verification and along with that obviously needs to calm a very strong management of that and i think we can look to the climate registry is setting a good example in that regard the amount of information that i as a verifier provide to them in order to be vetted in order to even embark on a verification with one of their members is very detailed and just simply asking the question i think helps start that for instance no member of our staff that has more than five thousand dollars personal interest in a company can perform any sort of verification work for that company their greatest risk i see however those is like i mentioned in my written testimony and here today is thinly veiled consulting and verification sides of the same company i think that it's fairly easy to engineer something like that on paper to say oh you know that's our consulting branch we don't have they don't do any verification work it's pretty easy to make it look that way on paper but i think when you really get out there in the field you can you can pierce a hole through that veil pretty easily so that would be our biggest word of warning and it's also why we as a business have made the absolute decision that we will not consult it just introduces risk i mean even if i don't personally know the person that did the consulting work and i'm the verifier if i still see my company logo on that report that i'm verifying i'm going to feel some amount of pressure to reflect positively on that work product so i think the simple there is a strong verification program well smooth in those market fluctuations because there's faith that that product actually exists and especially when you're talking greenhouse gas that you can't see and hold this one if i could add to that i think the key to the question was beginning with an extremely complex system an extremely complex system with added complexity because third party validation is that it is not going to get us there a far what's going to take additional time to develop your program what about a hybrid where you courage the voluntary self monitored thing and then there are adverse or positively consequences if the third party validates what you've done other words if you get it right you say we've lowered it by thirty percent these guys come along let me call you have lowered it by thirty percent you get a fabulous prize if if you don't you get a fabulous penalty there's a bit of that built into the climate registry right now and that the baseline verification is much stronger you're you're building it a relationship between the verifier and the reporter and saying ok you have the internal management structure to understand your inventory and manage this program well and then every annual subsequent verification can be ratcheted down a bit because you have faith in the system you're just verifying the system still in place not necessarily every single work product of the system so there that has been acknowledged i think well by the climate registry chairman for following up on that maybe could you lead me through an example mr ellis of how verification might work when in a particular business was a waste management has a a site  how would you go about verifying their compliance with a cap and trade voluntary cap and trade with how does it work so well for instance in the climate registry where it's a voluntary inventory program it's a  simple flowchart if you want to call it that were initially we gather remotely all their data as much as they can send us and we take a representative sample for example electricity usage say we would look at their spreadsheet by which they tracked that electricity usage and then we'd ask them to send us daniel whereis bills and we look and learn how that interface happens how to get from the bill or the meter or whatever to the spreadsheet and we deconstruct every bit of that data and then rebuild it and see if we come up with the same numbers and then that serves as a risk analysis to say where is the most inherent risk where did they most likely missa meter or you know miss miss  documents and information something along those lines and that's when we go on site and specifically target those high risk areas in those areas that could most materially impact the verification and that process holds true i mean just as an example of the range that we deal with is a w m s we started our first barricade barricade and was a small scale ski resort and we embark next week on verification of one of the largest electricity generation transmission and distribution utilities in the united states mechanism holds true across almost literally as wide of a range of spectrum as you could possibly imagine in order to do this keys do you have to have already done the electric utility no actual generations of power in other words they know how much was nuclear how much was it is it is that easily discerned it is absolutely you know first we assess off site whether the bills are accurately transcribed i mean you can have simple data transcription errors that lead to a material impact but then on site and their case electricity was a huge component it was the overwhelming component of their inventory so we literally said ok we're in this building show me the meter you know and make sure that that meter marries up to what we've been sickly see on site so it can be physically verified absolutely and that's been a very important point earlier about the being simple to do because we don't want to add a burden if we can avoid the burden we want to not add a burden so you found it fairly easy to ferret out that information or it depends on the source in the case of electrical utility usage there are a grid standards published putting a value on the typical carbon impact of electrical generation in a particular state it averages and all the different sources and you can use that as the default value or if you are buying exclusively from a utility that uses green energy you can you can do your own formula from that utility but using the grid numbers provides pretty robust results in electricity being really and the green energy we produce we certainly valid a it as a as green energy i don't think i can really speak to the the subject of how to determine whether energy is is green or not but when you when you ask if i'm comfortable with the end result yes because a and invoice is ultimately audited as part of your financial data chances are if a company is paying an invoice it's accurate they're going to do something about it if they are overpaying and the seller is going to do something about it if they're underpaying so when you use let me just add that the i mean you mentioned electricity grid is home with genius and you can't tell whether your water electricity came from a nuclear plant or a wind farm or whatever but you can allocate you know if twenty percent of our energy comes from nuclear you can you can allocate the carbon emissions based on a lot of electricity so you couldn't you couldn't say this guy got was nuclear and he has a smaller carbon footprints and this guy who got it all from here earlier for your testimony but i've looked at it and i just have one question or is a set of questions for ms gravitar is that how you pronounce your name thank you and it has to do with voluntary versus mandatory you know reporting and standards because i've had experience in dealing with companies reporting labor practices internationally and there are many mixed messages about how and whether these kind of voluntary reporting systems can work when it essentially is sort of self policing and so i wonder if you could explore with me just for a bit about what kinds of incentives or not really enforcement mechanisms because it would be volunteer a voluntary it's a voluntary program but what kind of incentives can be in place that encourage companies to straightforwardly and accurately report and  what's what's in it for them i mean i looked at in your testimony and you indicated some of the reasons why folks would want to participate in a reporting program but what's in it for them in the end and then lastly if you could talk to us about how one might make a transition from a voluntary system to a mandatory system and then what are the sets of of things that need to be in place in order to encourage compliance even in a mandatory system thank you for your questions i think the first thing to understand is that while the registry is voluntary program is voluntary and that you elect to participate it is not in fact self policing we have third party verifiers such as advanced waste management who must review and attest to the quality of the data that is reported so you can't voluntarily choose which emissions you're going to report rather you voluntarily choose to participate in the program and then the data that you report is reviewed by a third party verification body annually so that's a bit different what's in it for companies  said earlier companies cannot manage what they don't measure so it's very valuable for organizations to understand their corporate wide footprint so we can identify where there are opportunities for reductions that may  lead to emission reduction projects that create financial value to them it may also just be an efficiency approach for them where they can identify pollution if you will that they can reduce and and act more  effectively in terms of a transition from voluntary to mandatory i think we're thinking of this from the mindset of most organizations will likely report mandatory missions first so i think it's sort of flipping the question how can mandatory data be then used in a voluntary world assuming a company is required to report to a mandatory program that's likely going to be the facilities that trigger a certain threshold of emissions of their largest sources of emissions and then to supplement that for the full corporate footprint if you will can that data be trance the mandatory data be transferred into a more robust voluntary database if you will where the organization corral and out the rest of their emissions footprint that's how we're seeing the the intersection between mandatory reporting which will likely be at a certain threshold to voluntary reporting that will be more comprehensive in scope  and then are there incentives in terms of a company's relationship to a consumer or client that would encourage greater participation i think some companies are more aware and more concerned about the public perception and want to be seen as an environmentally progressive organization or particularly concerned about their emissions footprint so i think there's just a different risk assessment and interest in that from a corporate perspective i mean if you look now for example like leave standard lead certification i mean you know now there are developers out there who say they want that lead certification i mean and we haven't really had to do very much to necessarily to require it but it's become kind of an industry montra and i wonder if there is a similar application in the area of emissions well i think there's certainly the possibility we've seen from the california climate action registry which has a voluntary registry when the state of california implemented mandatory reporting we thought this will be an interesting observation will those companies that signed up for a voluntary program drop off and just participate in the mandatory program or will they maintain both and what we've seen thus far even though it's very early in the process is that companies are staying in the voluntary registry because they derive value associated with that so we we expect to see and hope to see a similar experience it'll be very interesting to see how mandatory greenhouse gas emissions are required to be reported at the federal level to see how organizations react to that thank you very much thank you very much ion joy the waste management ads on television they have such uncivil nature scenes but every time i see that ad i'm reminded all the burning that stuff is kind of green that way stream represents profit use of fossil fuels doesn't it and so in an increasingly energy efficient world there's going to be less and less of that waste stream and wouldn't it be greener to not have used that stuff so that doesn't end up in the landfill that's just an observation how close are we to being able to have truth in advertising i'm not a big fan of government and government regulation but i am a huge fan of truth in advertising and labeling how close are we so that we can tell because tumor and probably have to use something like c o two equivalents because that's what people are understanding about contribution to to climate change and global warming how close are we to telling the guy what this action will entail in terms of c o two equivalent footprint like when you sit down to eat that big beef steak if the guy it's a big red letters on the menu it told him that that was going to a bigger carbon footprint than driving his explorer there to eat it don't you think we might have some change in behavior because i think most people are really concerned about this but they're ignorant they don't know what they're doing how close are we that we can put down just about any activity you would like footprint so why are we putting that down on the menu and on the gas pump and on your thermostat in your house if you turn it up to degrees what's that c o two footprint why are we doing that i think people would like to know the contributions they're making so they can use less destructive pursuits and products and so forth is that something we need to do or is that something the industry can voluntarily and not a big fan of big brother by the way i would like industry to lay what is an industry lead in doing this well as an example we have been engaged in greenhouse gas inventorying and reduction efforts since two thousand and four and it's still voluntary we're still doing it still advancing it and we plan to disclose our company carbon footprint for two thousand and  that's on a website somewhere it's not on your lectern village not on your menu it's not listed on the products you buy in the grocery store everything we buy everything we do you just can't live that use energy without having a c o two equivalent footprint canyon why are we being told what that is so that we can make wise choices we have the capability to do it don't we but what we at least make a reasonable  equivalent contribution of everything we buy and everything we do and so i want that need desirable to have that there so that people can see it would but the quickest way to do it is to mandate it and less there is public pressure to have such information see the way it happens the quickness of there's a great demand from the public to have better information on the carbon footprint of everything they do there are many websites that individuals can go on and estimate their own carbon footprint for example but how many people do you think do it they just they just don't for whatever reason but it's so easy to see it if it's on the gas pump and on your menu it's on the box that curios you buy it so easy to see it there and i would just like to see it i would encourage industry to do this before government tells them to do it you know that just encourages government to get bigger when we have to when we when industry doesn't do something and then they're forced to do it because we asked them to do it i would hope that you would encourage the integers you all are associated with  start putting the c o two leap of a carbon footprint on everything that you sell on all of our activities so that americans know the contribution that they're making to to potential global warming and i think most of us want to be responsible but you know there's ignorance out there about the consequences of our activities well thank you very much thank you mr chairman for a good hearing thank you a spartan i want to ask one to do another round i just want to talk a little bit briefly about how can we scale this up internationally if we go to copenhagen if we go to international cap and trade or something like ok publ are other countries of learning our way of exploiting this and we don't have it yet in our own country so it's presumptuous i suppose we export it but this one asserts and others seem to verify that we can get a pretty good estimate of carbon footprint and we seem to think that either with a combination of upstream or downstream albeit with some imperfections we might be able to get a pretty good sense of how do we scale up globally well i think you kind of answered answered your question in the asking we do need to do a little more here before we can scale it up and a good start is to provide a uniform base to do a small amount of reporting a limited reporting scope and then allow the states to enhance that to perhaps require more data or more intense data and compile that to come up with our own carbon footprint and then we can lead through example to say i think you need to start where the information is the best right now in carbon and then work on the other greenhouse gases in increasing complexity as better information becomes available on the other gases  programs that have been operating in an international level level a lot longer than we've been in the conversation so as opposed to looking at it maybe as an export situation we can pay attention to the import situation there's a lot of good science and a lot of good real life market experience out there they've gone through a number of course corrections in the european emissions trading scheme and there are a number of other international trading schemes out there so i think that the question also should include what can we import it's a and there are certain other manufacturers that are working on making electronics automobiles central farm recyclable that our hours are so it's a very very good point mr inglis do you have any additional questions with that then i want to thank our witnesses for an outstanding and informative hearing today the record will remain open for two weeks for additional statements for the members and for answers to any follow up questions the committee at me ask of witnesses but that the witnesses refused in the hearing is now jerry and i thank the witnesses and all those in