a

GAO

United States Government Accountability Office

Report to Congressional Requesters

April 2006 CLIMATE CHANGE

EPA and DOE Should 

Do More to Encourage 

Progress Under Two 

Voluntary Programs

GAO-06-97
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

April 2006

CLIMATE CHANGE

EPA and DOE Should Do More to 

Encourage Progress Under Two 

Voluntary Programs 

Highlights of GAO-06-97, a report to 

congressional requesters 

To reduce greenhouse gas

emissions linked to climate change, 

two voluntary programs encourage 

participants to set emissions 

reduction goals. The Climate 

Leaders Program, managed by the 

Environmental Protection Agency

(EPA), focuses on firms. The 

Climate VISION (Voluntary

Innovative Sector Initiatives: 

Opportunities Now) Program, 

managed by the Department of

Energy (DOE) along with other 

agencies, focuses on trade groups.

GAO examined (1) participants’ 

progress in completing program 

steps, the agencies’ procedures for 

tracking progress, and their 

policies for dealing with 

participants that are not 

progressing as expected; (2) the

types of emissions reduction goals 

established by participants; and (3) 

the agencies’ estimates of the share

of U.S. greenhouse gas emissions 

that their programs account for and 

their estimates of the programs’ 

impacts on U.S. emissions.

What GAO Recommends

GAO recommends that DOE 

develop a system for tracking 

groups’ progress in completing 

program steps. Also, GAO 

recommends that both agencies

develop written policies on what to

do about participants not 

progressing as quickly as expected. 

EPA did not comment on the 

recommendation, and DOE agreed

with the recommendation on a 

tracking system and said it will 

consider the recommendation on

establishing a written policy. 

EPA expects Climate Leaders firms to complete several program steps 

within general time frames, but firms’ progress on completing those steps is 

mixed. For example, EPA asks firms to set an emissions reduction goal, 

generally within 2 years of joining. As of November 2005, 38 of the 

program’s 74 participating firms had set a goal. Of the 36 firms that had not 

set a goal, 13 joined in 2002 and thus took longer than expected to set a goal. 

EPA is developing a system for tracking firms’ progress in completing these 

steps, but it has no written policy on what to do about firms that are not 

progressing as expected. Trade groups generally established an emissions 

reduction goal before joining Climate VISION, and DOE generally expects 

them to develop a plan for measuring and reporting emissions within about 1 

year of joining. As of November 2005, 11 of the 15 participating groups had 

such a plan, but 2 of the groups without a plan joined in 2003, the program’s 

first year. DOE has no means of tracking trade groups’ progress in 

completing the steps in their plans and no written policy on what to do about 

groups that are not progressing as expected. A tracking system would 

enable the agency to ascertain whether participants are meeting program 

expectations in a timely manner, thereby helping the program to achieve its 

goals. By establishing a written policy on the consequences of not 

progressing as expected, both agencies could better ensure that participants 

are actively engaged in the programs, thus helping to achieve the programs’ 

goals.

The types of emissions reduction goals established by Climate Leaders firms

and Climate VISION groups vary in how reductions are measured and the 

time periods covered, among other things. For example, one Climate 

Leaders firm’s goal is to reduce its domestic emissions by 5 percent over 10

years; another’s is to reduce its worldwide emissions per dollar of revenue 

by 35 percent over 7 years. Similarly, one Climate VISION group’s goal is to 

reduce emissions of one greenhouse gas by 10 percent, while another’s is to 

reduce its emissions per unit of output by 12 percent. GAO noted that some

Climate VISION groups said meeting their goals may be linked to reciprocal 

federal actions, such as tax incentives or regulatory relief. 

EPA officials estimated that the first 50 firms to join Climate Leaders 

account for at least 8 percent of U.S. greenhouse emissions. DOE estimated 

that Climate VISION participants account for at least 40 percent of U.S. 

greenhouse gas emissions. EPA and DOE are working through an 

interagency process to quantify the emissions reductions attributable to their 

programs; the process is expected to be completed in 2006. However,

determining the reductions attributable to each program will be challenging 

because of the overlap between these programs and other voluntary 

programs, as well as other factors. 

 

www.gao.gov/cgi-bin/getrpt?GAO-06-97. 

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact John

Stephenson at (202) 512-3841 or

stephensonj@gao.gov. 
Page i GAO-06-97 Climate Change 

Contents

Letter 1

Results in Brief 3

Background 5

Some Climate Leaders and Climate VISION Participants Have Not 

Completed Program Steps as Soon as Expected, and Both 

Agencies Lack a Written Policy for Dealing with Such

Participants 10

Working with Federal Agencies, Most Participants in Both Programs 

Have Set Quantitative Emissions-Related Goals, Although Some 

Climate VISION Goals Were Qualified Based upon the Asserted 

Need for Reciprocal Federal Actions 17

Both Agencies Have Estimated Their Programs’ Coverage and Are 

Working to Estimate Their Impact, but It Will Be Difficult to 

Determine Specific Emissions Reductions from Each 

Program 26

Conclusions 31

Recommendations 33

Agency Comments and Our Evaluation 33

Appendixes

Appendix I: U.S. Government Voluntary Climate Change Programs 35

Appendix II: Scope and Methodology 38

Appendix III: Climate VISION Participant Qualifying Statements 40

Appendix IV: Comments from Environmental Protection Agency 42

Appendix V: Comments from the Department of Energy 43

Appendix VI: GAO Contact and Staff Acknowledgments 46

Tables Table 1: Shares, Sources, and Global Warming Potentials of U.S. 

Greenhouse Gas Emissions, 2003 6

Table 2: Climate Leaders’ Goals as of November 2005 20

Table 3: Climate VISION Trade Groups’ Goals as of November

2005 23

Table 4: Climate Leaders’ Carbon Dioxide Emissions from 

Electricity Generation (i.e., Power Plants Only), 2000 27

Table 5: Other U.S. Voluntary Greenhouse Gas Emissions 

Reduction Programs 35
Contents

Page ii GAO-06-97 Climate Change 

Figures Figure 1: U.S. Energy and Emissions Intensity Trends, 1990-2025 8

Figure 2: Climate Leaders Members’ Participation in Other 

EPA-Sponsored Voluntary Programs, as of November 

2005 30

Abbreviations

DOE Department of Energy

EIA Energy Information Administration

EPA Environmental Protection Agency

GHG Greenhouse gas 

HFCs Hydrofluorocarbons

IMP Inventory Management Plan

MMTCE Million metric tons of carbon equivalent

PFCs Perfluorocarbons

SF6 Sulfur hexafluoride

USDA U.S. Department of Agriculture

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately.
Page 1 GAO-06-97 Climate Change 

United States Government Accountability Office

Washington, D.C. 20548

A

April 25, 2006 Letr

The Honorable John McCain

The Honorable John Kerry

United States Senate

For over a century, scientists have known that concentrations of carbon 

dioxide and other greenhouse gases can alter the atmosphere in ways that 

affect the earth’s climate. Humans continue to release large quantities of 

carbon dioxide and other greenhouse gases into the atmosphere through, 

among other things, the combustion of fossil fuels, industrial and 

agriculture processes, landfills, and some land use changes. In 1992, the 

United States ratified the United Nations Framework Convention on 

Climate Change, which has as its objective the stabilization of greenhouse 

gas concentrations in the earth’s atmosphere but does not impose specific 

goals or timetables for limiting emissions. In response, federal agencies 

developed a plan for reducing greenhouse gas emissions, primarily through 

voluntary efforts by companies, state and local governments, and other 

organizations. Since that time, federal agencies have sponsored voluntary 

programs that encourage private and public sector entities to curb their 

greenhouse gas emissions by providing technical assistance, education, 

research, and information sharing. The administration has promoted such 

voluntary programs, along with other measures, as an alternative to 

mandatory emissions reductions.

In February 2002, the President announced a Global Climate Change 

Initiative to reduce the rate of increase in greenhouse gas emissions in the 

United States. Specifically, he established the goal of reducing the 

emissions intensity of the United States by 18 percent between 2002 and 

2012. Emissions intensity is a ratio calculated by dividing emissions in a 

given year by economic output for that year. In support of this goal, the 

President announced two new voluntary programs aimed at securing 

private sector agreements to voluntarily reduce greenhouse gas emissions 

or emissions intensity. 

• Climate Leaders, an Environmental Protection Agency 

(EPA)-sponsored government-industry partnership established in 

February 2002, works with firms to develop long-term climate change 

strategies. According to EPA officials, as of November 2005, 74 firms 

were participating in the program.
Page 2 GAO-06-97 Climate Change 

• Climate VISION (Voluntary Innovative Sector Initiatives: Opportunities 

Now), introduced in February 2003 and coordinated by the Department 

of Energy (DOE) in cooperation with EPA and other federal agencies, 

works with trade groups to develop strategies to reduce their members’ 

greenhouse gas emissions intensity. Most industries participating in the 

program are represented by a single trade group. As of November 2005, 

14 industry sectors and the Business Roundtable—an association of 

chief executive officers representing diverse sectors of the 

economy—were participating in the program. According to DOE, the 

trade groups participating in Climate VISION typically have high energy 

requirements. 

This report examines the progress EPA and DOE have made in 

implementing their respective programs. Specifically, for each program, 

this report discusses (1) the key steps that the agencies expect participants 

to complete (such as preparing a plan for measuring emissions and 

reporting data), the progress participants have made in completing these 

steps, the agencies’ efforts to track participants’ progress, and the agencies’ 

strategies for dealing with participants not progressing as expected; (2) the 

types of emissions or emissions intensity reduction goals being established 

by participants in this program; and (3) the agencies’ estimates of the 

programs’ current coverage (that is, the share of U.S. emissions that 

participants contribute to total U.S. emissions) and impact (in terms of 

emissions reduced). In addition, as you requested, a list of other federal 

voluntary climate change programs is presented in appendix I. 

In conducting our work, we reviewed and analyzed EPA and DOE 

documents on the Climate Leaders and Climate VISION programs, as well 

as other voluntary climate programs and met with these agencies’ officials. 

For the sake of brevity, we refer to all participants in the Climate Leaders 

programs as firms, even though one of them, the National Renewable 

Energy Laboratory, is a federal research laboratory. Similarly, we refer to 

all Climate VISION participants as trade groups, even though one 

participant, the Tennessee Valley Authority, is a utility. For the sake of 

consistency, we describe both Climate Leaders and Climate VISION 

participants’ emissions or emissions intensity targets as goals, even though 

DOE describes Climate VISION participants’ targets as commitments. Most 

of the information in the report, except where otherwise noted, reflects the 

status of the two programs as of November 2005. As of March 2006, an 

additional 10 firms had joined Climate Leaders. To assess the reliability of 

the EPA, DOE, and other data, we spoke with agency officials about data 

quality control procedures and reviewed relevant documentation. We 
Page 3 GAO-06-97 Climate Change 

determined that the data were sufficiently reliable for the purposes of this 

report. We conducted our work between June 2004 and March 2006 in 

accordance with generally accepted government auditing standards, 

including an assessment of data reliability. Additional details on our scope 

and methodology are presented in appendix II.

Results in Brief EPA and DOE each expect participants in their voluntary emissions 

reduction programs to complete a number of actions; however, 

participants’ progress toward completing those actions, as well as the 

agencies’ efforts to track accomplishments, has varied. For example, 

within about 1 year of joining the program, EPA expects firms to enter into 

discussions with the agency to establish an emissions reduction goal and to 

complete these negotiations, generally within another year. As of 

November 2005, 38 of the 74 firms had established goals, while most of the 

other 36 firms, including 13 that joined in 2002, were still working to 

establish goals; most of the remaining firms had joined the program 

recently and had not yet established goals. EPA officials told us that they 

were developing a system for tracking firms’ progress in accomplishing the 

key steps associated with program participation, but are still in the process 

of obtaining and validating data from participants. While EPA officials told 

us that they would be willing to remove participants from the program if 

they were not progressing as expected, they have not specified the 

conditions under which they would do so. DOE asks that trade groups 

participating in its Climate VISION Program develop a work plan for 

measuring and reporting emissions information within about 1 year after 

joining the program and later report their emissions levels. As of November 

2005, 11 of the 15 participating trade groups had completed their work 

plans and 5 groups had reported on emissions. As of November 2005, DOE 

officials said that the agency did not have a system for tracking how long 

each group takes to complete its work plan and report emissions data. 

Furthermore, they said that DOE would remove groups from the program if 

they did not seem to be taking sufficient action. However, DOE has not yet 

established specific deadlines for reporting emissions. Because DOE does 

not have a system for tracking how long participants take to complete key 

program steps--and neither agency has established written policies for 

taking action against entities not progressing as expected--it will be 

difficult for the agencies to ensure that all participants are meeting 

expectations, and hence that the programs are contributing to meeting the 

President’s emissions intensity reduction goal.
Page 4 GAO-06-97 Climate Change 

The specific types of emissions reduction goals being established by 

Climate Leaders firms and Climate VISION groups varied. Of the 38 firms 

participating in Climate Leaders that had established emissions reduction 

goals as of November 2005, 19 committed to reduce their total greenhouse 

gas emissions, 18 committed to reduce their emissions intensity (emissions 

per unit of output), and 1 firm committed to reduce both its total emissions 

and its emissions intensity. Furthermore, firms’ goals differed in their 

geographic scope and the time period they covered. For example, Cinergy 

Corporation pledged to reduce its total U.S. domestic greenhouse gas 

emissions by 5 percent from 2000 to 2010, while Pfizer, Inc., pledged to 

reduce its worldwide emissions by 35 percent per dollar of revenue from 

2000 to 2007. In contrast to EPA’s program, 14 of the 15 trade groups 

participating in Climate VISION established an emissions-related goal in 

collaboration with DOE or another federal agency upon joining the 

program. (The remaining group, the Business Roundtable, did not establish 

a quantitative emissions goal because of the diversity of its membership.) 

According to a DOE official, participants need not establish new goals as a 

condition of joining the program. Nine of the 14 groups set goals to improve 

their emissions intensity, 2 groups established a goal of reducing emissions 

of specific greenhouse gases, 2 groups set goals to improve energy 

efficiency, and 1 group established a goal of both reducing its total 

emissions and improving its energy efficiency. For example, the American 

Forest & Paper Association pledged to reduce emissions intensity by 12 

percent between 2002 and 2012, while the American Iron and Steel Institute 

agreed to a 10-percent, sector wide increase in energy efficiency by 2012. 

Some of these groups stated that their goals would be difficult to achieve 

without reciprocal federal actions, such as tax incentives or regulatory 

relief.

EPA and DOE both estimated the share of total U.S. greenhouse gas 

emissions attributable to participants in their respective programs and are 

working to develop an estimate of the programs’ impacts. EPA estimated 

that Climate Leaders participants accounted for at least 8 percent of U.S. 

emissions. This is a conservative estimate, according to EPA, because it 

was based solely on emissions from the program’s first 50 participants. 

DOE estimated that Climate VISION participants account for over 40 

percent of U.S. greenhouse gas emissions and noted that this estimate is 

conservative. Both agencies are participating in an interagency process to 

estimate the effect of their programs on reducing emissions, which is 

expected to be completed in 2006. However, preparing accurate estimates 

of these programs’ impacts will be difficult. First, there is considerable 

overlap between these two programs and other voluntary programs. For 
Page 5 GAO-06-97 Climate Change 

example, 60 of the 74 Climate Leaders participants also participate in one 

or more other EPA programs, and 3 of the 14 Climate VISION participants 

with quantitative goals also participate in EPA voluntary programs. Such 

overlap makes it difficult to determine the effects that are attributable to a 

given program. Second, it will be difficult to determine how much of a 

firm’s or trade group’s emissions reductions can be attributed to its 

participation in the program because the level of a participant’s emissions 

in the absence of the program is unknown. For example, higher energy 

prices or changes in business operations could produce emissions 

reductions, making it difficult to distinguish reductions attributable to 

participation in the program versus other causes.

To ensure that the Congress and the public have information with which to 

evaluate the effectiveness of these voluntary programs and to increase the 

opportunities for these programs to contribute to the President’s emissions 

intensity reduction goal, we are recommending that DOE develop a system 

for tracking participants’ progress in completing key steps associated with 

the program. Also, we are recommending that both EPA and DOE develop 

written policies that establish the actions the agencies will take if 

participants are not completing program steps on time. We provided EPA 

and DOE with a draft of this report for their review and comment. EPA did 

not comment on our recommendation to the agency. DOE stated that the 

report provided a useful overview of the Climate VISION program. It 

agreed with our recommendation on a tracking system and said it will 

consider our recommendation regarding a written policy. EPA’s and DOE’s 

written comments are included in appendixes IV and V, respectively.

Background Carbon dioxide is by far the most prevalent greenhouse gas emitted in the 

United States, as shown in table 1. The other principal greenhouse gases, in 

order of percentage of emissions in 2003, are methane, nitrous oxide, and 

three types of synthetic gases—hydrofluorocarbons (HFCs), 

perfluorocarbons (PFCs), and sulfur hexafluoride (SF6).
Page 6 GAO-06-97 Climate Change 

Table 1: Shares, Sources, and Global Warming Potentials of U.S. Greenhouse Gas 

Emissions, 2003

Source: EPA.

Note: Components do not sum to 100 percent due to independent rounding.

a

Since greenhouse gases differ in their potential to contribute to global warming, each is assigned a 

unique weight, called a global warming potential, which is based on its heat-absorbing ability relative to 

carbon dioxide over a fixed time period. This provides a way to convert emissions of various 

greenhouse gases into a common measure, such as carbon equivalent. Thus, each molecule of 

methane, for example, has 21 times as much effect on warming as a molecule of carbon dioxide. 

In response to the May 1992 United Nations Framework Convention on 

Climate Change, the United States developed the Climate Change Action 

Plan aimed at reducing domestic greenhouse gas emissions. As a part of 

this plan, programs were developed during the 1990s to provide 

information and tools to encourage participants to voluntarily undertake 

changes to reduce their emissions of carbon dioxide, methane, and other 

greenhouse gases. The intent of programs such as Energy STAR is to help 

organizations improve energy efficiency, thereby helping to reduce 

emissions. Other programs, such as the Coalbed Methane Outreach 

Program, encourage emissions reductions in other greenhouse gases, such 

as methane. 

The amount of energy used to generate each dollar of national output has 

declined over time. The ratio of energy used to economic output is called 

energy intensity. According to the Energy Information Administration 

(EIA), the independent statistical and analytical agency within DOE, energy 

intensity declined between 1990 and 2003, at an average rate of 1.8 percent

Greenhouse gas Major sources

Percentage 

of 2003 

emissions

Global 

warming 

potentiala

Carbon dioxide Fossil fuel combustion, nonenergy use of 

fuels, iron and steel production

85 1

Methane Landfills, natural gas and petroleum 

systems, agriculture, coal mining

8 21

Nitrous oxide Agricultural soil management, 

transportation, manure management

6 310

Synthetic gases Substitution of ozone-depleting 

substances, electric power transmission 

and distribution, aluminum production

2 140 to 

23,900
Page 7 GAO-06-97 Climate Change 

per year.

1

 The rate of decline was the result of, among other things, energy 

efficiency improvements in industrial and transportation equipment and in 

commercial and residential lighting, heating, and refrigeration 

technologies.

2

 In early 2006, EIA projected that energy intensity will decline 

at an average annual rate of 1.8 percent between 2005 and 2025.

3

The U.S. economy has also become more efficient in terms of emissions 

intensity. (According to EIA, energy and emissions intensity are closely 

related because energy-related carbon dioxide emissions make up more 

than 80 percent of total U.S. greenhouse gas emissions.)4

 U.S. emissions 

intensity declined between 1990 and 2003 at a rate of 1.9 percent a year. The 

reasons for the decline include general improvements in energy efficiency 

and a long-term shift toward a service economy. Other reasons include 

greater use of nuclear power, development of renewable resources, 

substitution of less emissions-intensive natural gas for coal and oil, and the 

use of transportation fuels with biogenic components, such as ethanol. EIA 

projected in early 2006 that between 2005 and 2025, emissions intensity will 

decline at a rate of 1.7 percent per year (see fig. 1).5

1

EIA, Annual Energy Outlook 2005, DOE/EIA-0383(2005) (Washington, D.C.: February 

2005).

2

EIA, Emissions of Greenhouse Gases in the United States 2003, DOE/EIA-0573(2003) 

(Washington, D.C.: December 2004).

3

EIA, Annual Energy Outlook 2006, DOE/EIA 0383(2006) (Washington, D.C.: February 

2006). 

4

EIA, Emissions of Greenhouse Gases in the United States 2003, DOE/EIA-0573(2003) 

(Washington, D.C.: December 2004).

5

EIA, Annual Energy Outlook 2006, DOE/EIA 0383(2006) (Washington, D.C.: February 

2006).
Page 8 GAO-06-97 Climate Change 

Figure 1: U.S. Energy and Emissions Intensity Trends, 1990-2025

Note: These data are used for background purposes only to demonstrate trends in U.S. energy and 

emissions intensity. We did not assess the reliability of the data.

a

Emissions intensity is defined as metric tons of carbon dioxide equivalent per million constant (2000) 

dollars of gross domestic product.

b

Energy intensity is defined as thousand British thermal units (Btu) per constant (2000) dollars of gross 

domestic product.

The goal of the President’s 2002 initiative was to reduce the emissions 

intensity of the U.S. economy by 18 percent between 2002 and 2012, a 

reduction 4 percentage points greater than would be expected absent any 

new policy. In particular, according to EIA projections cited by the 

administration, without the initiative, emissions would increase from 1,917 

million metric tons of carbon equivalent (MMTCE)6

 in 2002 to 2,279 

MMTCE in 2012. Under the initiative, emissions will increase to 2,173

6

Carbon equivalent is a metric measure commonly used to compare the emissions of 

different greenhouse gases based on their different specific contributions to warming the 

atmosphere.

0

250

500

750

1,000

202

2024

2025

3

201

2014

2015

2016

2017

2018

2019

2020

2021

2022

3

200

2004

2005

2006

2007

2008

2009

2010

2011

2012

3

199

1994

1995

1996

1997

1998

1999

2000

2001

2002

3

1990

1991

1992

0

3

6

9

historic trend projected trend 12

Emissions intensitya Energy intensityb

Energy intensity

Emissions intensity

Source: EIA.

Year
Page 9 GAO-06-97 Climate Change 

MMTCE in 2012, which is 106 MMTCE less than otherwise expected.

7

 In 

2002, EIA projected that U.S. emissions intensity would decline (improve) 

by 14 percent between 2002 and 2012 without any new policy. In 2006, EIA 

updated its estimate, projecting a decline in emissions intensity of 17 

percent between 2002 and 2012. According to EIA, further reductions in 

emissions intensity are projected to result from, among other things, 

increasing energy prices that will tend to reduce energy consumption 

growth below prior estimates. Nevertheless, according to this estimate, 

total greenhouse gas emissions will continue to rise. Specifically, EIA 

projected in 2006 that total emissions would increase by 14.2 percent 

between 2002 and 2012.

8

The President’s 2002 initiative comprised about 30 elements. In addition to 

challenging businesses and industry to voluntarily reduce emissions, it 

included tax incentives for renewable energy and conservation, 

transportation programs, and other efforts. Climate Leaders and Climate 

VISION are two of the federal government’s newest voluntary climate 

programs. According to a DOE official, they are the only federal programs 

that ask potential members for an emissions or emissions intensity 

reduction goal in order to participate. According to EPA, for firms that are 

already participating in other EPA voluntary programs, Climate Leaders 

can serve as a coordinating umbrella to comprehensively manage their 

voluntary climate change activities.

7

See GAO’s October 2003 testimony, Climate Change: Preliminary Observations on the 

Administration’s February 2002 Climate Initiative, GAO-04-131T (Washington, D.C.: Oct. 

1, 2003). 

8

EIA, Annual Energy Outlook 2006, DOE/EIA 0383(2006) (Washington, D.C.: February 

2006).
Page 10 GAO-06-97 Climate Change 

Some Climate Leaders 

and Climate VISION 

Participants Have Not 

Completed Program 

Steps as Soon as 

Expected, and Both 

Agencies Lack a 

Written Policy for 

Dealing with Such 

Participants

According to EPA officials, all program participants agree to complete four 

program steps, and EPA guidelines suggest that these steps generally be 

completed within about 1 year, although the goal negotiation process can 

take as long as 2 years. The first step is to prepare a greenhouse gas 

emissions inventory; the second step is to prepare an inventory 

management plan (IMP); the third step is to enter into negotiations with 

EPA regarding a goal; and the fourth step is to report annually. (However, 

EPA does not insist that firms perform all four steps in that order). Overall, 

we found that some firms were taking longer to complete these steps and 

that EPA has no written policy for dealing with such firms. According to 

DOE officials, all program participants agree to complete two program 

steps: the first within about 1 year of joining the program, and the second 

after they have finished training their members in the use of reporting 

protocols, most in 2006. Overall, we found that some groups had not 

completed the first step within the specified time frame. EPA has started to 

develop a system for tracking participants’ progress; DOE does not yet 

have such a system. Neither agency has written criteria detailing expected 

time frames for meeting expectations or the consequences of not meeting 

expectations.

EPA Expects Firms to 

Complete Certain Program 

Steps, but Not All Have 

Done So 

First, firms complete their base-year inventories, which EPA encourages 

and expects them to do, on average, within 1 year of joining the program. 

The base-year inventory contains the data that will be used to measure 

firms’ progress toward their goals. As of November 2005, 61 of the 74 firms 

had submitted base-year inventory data to EPA. After the inventory has 

been submitted, the participant works with EPA to refine its inventory. 

Eleven of the 61 inventories had been finalized and approved by EPA. The 

other 50 were still in development or review. An EPA official noted that 

some firms did not submit inventories earlier because EPA’s reporting 

guidelines were not completed until April 2004. In addition, these officials 

told us that it often takes firms more than a year to prepare their base-year 

inventory because firms start at different levels of sophistication with 

respect to developing an inventory. Some firms start with no knowledge of 

how to develop an inventory and no infrastructure in place for doing so. 

Furthermore, some corporate inventories may take longer due to their 

complexity, including complicated corporate structures, a wide variety of 

emissions sources, and the lack of available emissions data. Corporate 

reorganizations and staff turnover also contribute to delays. An EPA 

official told us that the average amount of time it takes firms to complete 

their base-year inventory once they join the program has been 2 years, but 
Page 11 GAO-06-97 Climate Change 

the average amount of time firms have taken since EPA completed its 

reporting guidelines is 1 year. 

Firms have two options for having their inventories reviewed. They can 

either submit their data to EPA for review, or they can choose third-party 

verification, in which an outside organization, such as an environmental 

engineering firm with greenhouse gas verification experience, reviews their 

data.

After they have submitted base-year inventory data to EPA, firms work 

with EPA to refine the inventory, usually resulting in some revisions. In 

reporting data, firms are to follow guidance developed by EPA that is based 

on a standardized reporting protocol established by the World Resources 

Institute and the World Business Council for Sustainable Development.9

The protocol consists of corporate emissions accounting standards 

developed by representatives from industry, government, and 

nongovernmental organizations. 

Second, EPA officials told us that EPA expects all firms to prepare an IMP, 

which is the firm’s plan for collecting data, preparing the inventory, and 

managing inventory quality. EPA officials informed us that, as of November 

2005, 60 of the 74 firms had submitted draft IMPs. Firms that choose to 

have EPA review their emissions inventories must also submit their IMP to 

EPA, while firms that choose to undergo third-party verification must 

submit a letter from the third party stating that all the specified 

components of the IMP checklist are in place and that at least one site visit 

was conducted. The IMP checklist consists of 30 components in seven 

major categories, including, among other things, boundary conditions (i.e., 

which parts of the facility will be covered under the program), emissions 

quantification methods, and data management processes. Nineteen of the 

30 IMP components are to be in place within 1 year of joining the program 

and must be in place for base-year reporting to be finalized. Fifty-four of 

the 60 firms completing IMPs submitted their IMPs to EPA for review, while 

the other 6 chose to have their inventories and IMPs reviewed by third 

parties. According to EPA officials, the remaining 14 firms had not 

submitted a draft IMP or informed EPA of their intention to choose 

9

The World Resources Institute is a nonprofit environmental research and policy 

organization that, among other things, works to reverse global warming. The World 

Business Council for Sustainable Development is a coalition of 175 international companies 

that provides business leadership on sustainable development issues.
Page 12 GAO-06-97 Climate Change 

third-party verification, although eight of these firms joined the program 

within the past year and so, according to EPA officials, would not be 

expected to have completed these steps. EPA officials told us that these 

remaining firms are still working on the necessary documentation. 

EPA conducts at least one site visit per firm to review facility-level 

implementation of the IMP to determine whether there are ways to improve 

the plan’s accuracy, among other things. The site to be visited is mutually 

agreed upon; EPA aims to review the company facility with the highest 

overall risk to the accuracy of reported emissions. (Such a site should be a 

large emitter, have many of the largest emission types, and represent the 

firm’s most common business activity, among other criteria.) As of 

November 2005, EPA had conducted 25 site visits (about one-third of all 

firms), with 10 more visits scheduled before the end of 2005. 

The base-year inventory is not considered final until EPA has reviewed 

both it and the IMP and conducted a site visit. An EPA official told us that 

initial inventories generally contain about 95 percent of each member’s 

total emissions, so only minor and incremental revisions are needed at the 

on-site review stage. 

EPA provides up to 80 hours of technical assistance to help each firm 

complete its base-year inventory and develop and document its IMP. 

Technical assistance can include implementing greenhouse gas accounting 

methods as well as measuring, tracking, and reporting emissions. After the 

firm’s base-year inventory is complete, EPA experts continue to offer up to 

10 hours annually of technical assistance during subsequent years.

Since Climate Leaders provides technical assistance to each firm as it 

develops and documents its inventory and IMP, an EPA official stated that 

most major issues that might arise in inventory design and development are 

addressed informally at the technical assistance stage. However, according 

to EPA, some issues are identified during the site visits. In general, the site 

visits have identified only a few areas where EPA asked for revisions. 

These usually involved missing small sources of on-site emissions (such as 

those from propane for forklifts or on-site diesel purchases for a yard 

truck). EPA officials told us that most of the items they identified during 

the site visits were minor calculation errors or ways to improve the firm’s 

data quality assurance and quality control processes. They said that the 

majority of these areas are corrected on location during the site visit, and 

any others are verified by the submission of an updated IMP and 

greenhouse gas reporting form that describe respectively, the changes to 
Page 13 GAO-06-97 Climate Change 

the inventory process and the greenhouse gas emissions that were made in 

response to the findings. 

As noted earlier, firms choosing third-party verification instead of EPA 

review are to submit an independent verifier’s report stating that at least 

one site visit was conducted and that all the necessary components of the 

IMP checklist were successfully implemented. As of November 2005, six 

firms had chosen to have their data verified by a third party, and all of these 

firms had undergone their third-party verification. Three firms had 

submitted inventory data and initial auditor reports to EPA. EPA is awaiting 

letters from the other three firms indicating that all of the components of 

the IMP checklist are in place and that any corrective actions identified in 

the verification process have been addressed. 

Third, EPA officials told us that the agency expects firms to enter into 

negotiations with EPA to set their reduction goals once their base-year 

inventory is finalized, generally within about 1 year after joining the 

program, and to complete negotiations within 1 year after that. However, 

we found that some firms have taken longer to do so. Thirty-eight of the 74 

participating firms had set goals as of November 2005.

10 Of the 36 firms 

without goals, 20 were working with EPA to develop goals. Seven of these 

20 firms were still working on their base-year inventories, and 9 had joined 

the program within the past year and hence would not be expected to have 

set goals. The 36 firms without goals included 18 firms that joined the 

program in 2002 or 2003. Specifically, of the 35 firms that joined in 2002, the 

program’s first year, 22 had set goals, 9 firms were in the process of 

negotiating their goals with EPA, and 4 more had not begun such 

negotiations. Of the 16 firms that joined in 2003, 11 had set goals, 3 were in 

negotiation with EPA regarding goals, and 2 had not yet begun such 

negotiations. According to EPA officials, the 6 firms had not begun 

negotiations because their base-year inventories were not finalized. 

In describing why it may take a long time to set goals, EPA officials told us 

that many firms require considerable time to develop their inventories, 

which can be complex. Firms must also obtain internal approval of their 

emissions reduction goals from their senior management, and some firms 

lack enough resources to devote to inventory development to meet the time 

frame of EPA’s reporting guidelines. Other reasons also exist. For example, 

10EPA officials informed us that, as of March 20, 2006, 10 additional firms had joined the 

program, for a total of 84 firms, 46 of which had announced goals.
Page 14 GAO-06-97 Climate Change 

one firm disagreed with EPA regarding whether to report a certain type of 

emission in its inventory and needed to come to agreement with EPA on 

addressing those emissions. Another firm is involved in litigation that will 

likely affect its future emissions levels and does not want to set an 

emissions reduction goal until the case is resolved, while yet a third firm is 

facing regulation that could affect its ability to meet an aggressive 

reduction goal. 

Finally, according to EPA’s reporting guidelines, all firms agree to report to 

EPA annually on their emissions using EPA’s Annual Greenhouse Gas 

Inventory Summary and Goal Tracking Form. This form describes the 

firm’s emissions at a corporate level broken out by emissions type for both 

domestic and international sources and details progress toward the firm’s 

emissions reduction goal. As of November 2005, 10 of the 11 firms with 

finalized inventories had submitted annual data through 2004 to EPA. An 

EPA official told us that the other firm was currently resolving some 

outstanding issues and would likely submit a report in early 2006. 

Although all firms are expected to complete all four steps listed above, EPA 

officials told us that firms do not need to complete the steps in any 

particular order. For example, some firms may choose to finalize their 

base-year inventory before submitting annual reports with multiple years of 

data, while other firms may choose to submit annual data before the 

inventory is fully finalized.

EPA Is Developing a System 

to Track Participants’ 

Progress, but It Lacks a 

Written Policy for Dealing 

with Firms That Do Not 

Complete Program Steps in 

a Timely Manner 

EPA officials told us that they had started to develop a database to track 

firms’ progress and are currently in the process of entering and validating 

the data. Although some firms are not completing the various program 

steps as quickly as EPA expected, the agency has not yet established a 

written policy for dealing with such firms. An EPA official noted that firms 

that voluntarily agree to participate in the program are aware of program 

expectations and are generally proactive in meeting them. EPA officials 

further stated that the agency has three options for dealing with firms that 

do not appear to be proceeding in a timely manner: (1) telephone calls from 

EPA or its contractor to reinvigorate the process, (2) a letter to firms urging 

them to act more expeditiously, or (3) removal from the program if the firm 

is not putting forth a good-faith effort to meet the program’s expectations. 

However, EPA believes that it is better for the environment to work with 

firms that are making a good-faith effort to implement appropriate 

management systems than to remove them from the program. To date, EPA 

has not removed any firm from the program for lack of progress, although 
Page 15 GAO-06-97 Climate Change 

one firm voluntarily left after realizing it did not have sufficient resources 

to continue participation. According to EPA officials, as of November 2005, 

two firms did not appear to be working toward completing their reporting 

duties in a timely manner, and EPA anticipated sending letters to those 

firms. EPA officials noted that, since Climate Leaders is a voluntary 

program, it is difficult for EPA to sanction firms that do not meet all of the 

program’s expectations in a timely manner. These officials said that, 

although they do not currently have a written policy on how to deal with 

firms that are not progressing as expected, including specific standards for 

time frames and consequences, they expect to begin developing such a 

policy in the near future.

DOE Expects Trade Groups 

to Complete Two Steps, but 

Not All Have Done So

DOE has defined two program steps that it expects participating trade 

groups to complete: developing a work plan and reporting emissions data. 

According to agency officials, after establishing its goal to reduce 

emissions, each industry group is asked to develop a work plan following a 

standard template developed by DOE, generally within 1 year of joining the 

program. The template includes four items: (1) emissions measurement 

and reporting protocols; (2) plans to identify and implement near-term, 

cost-effective opportunities; (3) development of cross-sector projects for 

reducing greenhouse gas emissions intensity; and (4) plans to accelerate 

research and development and commercialization of advanced technology. 

However, DOE officials explained that specific elements of each industry 

group’s work plans are different because each industry is different. The 

work plans are intended to help ensure that the trade groups’ goals and 

activities are significant, clearly understood by the public, and aimed at 

producing results in a time frame specified by the group. 

Preparing the work plan is a collaborative process between the trade 

groups and program officials. Each work plan is reviewed three times by 

(1) a representative of the federal agency having the lead for that industry 

(e.g., DOE for the American Chemistry Council, and DOE and the 

Department of Agriculture for the American Forest & Paper Association); 

(2) Climate VISION program staff; and (3) a DOE contractor to ensure that 

the plan provides a suite of activities that will enable the group to meet its 

reduction goal. DOE officials told us that all work plans completed to date 

were subjected to at least one round of revisions before being finalized and 

posted to the program’s Web site. 

According to DOE officials, as of November 2005, 11 of the 15 trade groups 

had completed their work plans. Of the four groups that had not completed 
Page 16 GAO-06-97 Climate Change 

their work plans, two were new members, joining Climate VISION in 2005; 

the other two—the Association of American Railroads and the National 

Mining Association—were original members, joining in 2003. DOE officials 

said they were still working with the groups to finalize their work plans. 

They also noted that getting the trade groups to adhere to DOE’s time lines 

can be challenging because the groups often have to clear all their activities 

through their individual member companies or through their boards of 

directors, which can be time consuming. 

In addition to developing a work plan, trade groups are expected to report 

data on their greenhouse gas emissions. As of November 2005, 5 of the 15 

groups had reported data: 2 groups reported data to DOE, and 3 groups that 

have been working with EPA as participants in EPA-sponsored programs

reported to that agency. According to a DOE official, as the trade groups 

finish developing and training their members in the use of reporting 

protocols, they are expected to begin reporting on their emissions, most in 

2006. DOE will then ask the groups to report annually. Program officials 

explained that, at least in one case, a group did not report earlier because, 

among other things, DOE was revising its interim final voluntary emissions 

reporting guidelines, which were released in late 2005.

DOE does not specify a particular format that trade groups should use in 

reporting emissions data, since all industries are different and the nature of 

the goals differ. However, the program encourages the groups to have their 

individual members report using EIA’s Voluntary Reporting of Greenhouse 

Gases program11 or another appropriate reporting system, such as EPA’s. 

Trade groups have developed or are developing reporting protocols as part 

of their work plans. 

DOE officials told us that once they receive data from the trade groups, 

they would arrange for a contractor to review these data and check them 

against EIA or EPA data for the reporting industry’s sector for accuracy. 

The officials also told us they would post trade groups’ emissions reports 

on DOE’s Web site to provide transparency, thereby providing an incentive 

for groups to report accurate information. An industry may also choose on 

its own to hire an independent expert to review reports for accuracy. For 

example, the American Chemistry Council has required third-party 

certification of each of its member companies’ environmental, health, and 

11Section 1605(b) of the Energy Policy Act of 1992 directed DOE to issue guidelines 

establishing a voluntary greenhouse gas reporting program. 
Page 17 GAO-06-97 Climate Change 

safety and security management systems, including the program under 

which members measure and report greenhouse gas emissions. 

DOE Plans to Track 

Participants’ Progress in 

Completing Program Steps, 

but It Lacks a Written Policy 

For Dealing with Those That 

Do Not Progress as 

Expected

Program officials told us that they do not have a system for tracking 

participants’ actions, including completing work plans, reporting, and the 

other steps identified in its work plan, but they said a contractor is working 

to establish a reporting system for 2006. The officials also said that DOE 

would remove trade groups from the program if they did not appear to be 

taking actions to complete program steps, but DOE has not yet established 

any deadline by which groups’ emission reports must be submitted. 

However, the officials stated that they are currently working on setting 

such a deadline. The officials said that they do not believe it will be 

necessary to remove groups, since the groups are very enthusiastic about 

the program and understand the political stakes involved. Therefore, these 

officials expressed confidence that the groups will meet DOE’s 

expectations to the best of their abilities. 

Working with Federal 

Agencies, Most 

Participants in Both 

Programs Have Set 

Quantitative 

Emissions-Related 

Goals, Although Some 

Climate VISION Goals 

Were Qualified Based 

upon the Asserted 

Need for Reciprocal 

Federal Actions

EPA worked with firms to set emissions-related goals, and more than half 

of the firms participating in Climate Leaders have set goals for reducing 

their emissions or improving their emissions intensity. The firms’ goals 

vary in terms of the metric used, their geographic scope, and the time 

period covered. DOE or another federal agency conducted discussions 

with the industry groups on establishing their goals, and all participating 

groups had established a goal before joining Climate VISION. The 

participants’ goals varied in terms of the type of goal (emissions, emissions 

intensity, or energy efficiency) and the period covered by the goal (start 

and end dates.) Finally, many groups qualified their goals based upon their 

stated need for reciprocal federal actions, such as tax incentives or 

regulatory relief.
Page 18 GAO-06-97 Climate Change 

EPA Helps Firms Set Goals EPA works with all firms to set goals and offers flexibility in goal-setting, 

since each firm has a unique set of emissions sources and reduction 

opportunities. First, as discussed earlier, EPA works with firms to develop 

inventories and IMPs to document their base-year emissions. Second, EPA 

creates an industry standard, or benchmark, against which to evaluate each 

firm’s goal. EPA uses a suite of modeling tools and statistical tables to 

develop the benchmark for each industry sector. The firm’s goal is 

evaluated against a projected emissions improvement rate for its sector; 

EPA expects every firm’s goal to be markedly better than the projected 

benchmark for the firm’s sector. EPA also checks each firm’s reported 

emissions data over the goal period to ensure that the firms are not 

reducing emissions simply by shrinking their size or by outsourcing.

EPA encourages each firm to set a goal that is aggressive but that also 

considers company and sectoral variations. Nonetheless, each goal must be 

(1) entitywide (including at least all U.S. operations), (2) based on the most 

recent base year for which data are available, (3) achieved over 5 to 10 

years, (4) expressed as an absolute emissions reduction or as a decrease in 

emissions intensity, and (5) aggressive compared with the projected 

greenhouse gas emissions performance for the firm’s industry. 

More Than Half of the 

Participants in Climate 

Leaders Have Set Goals, and 

These Goals Vary

As of November 2005, 38 of the program’s 74 firms had set emissions or 

emissions intensity reductions goals. The remaining 36 firms were working 

with EPA to set goals. The firms’ goals vary in terms of three 

characteristics: (1) the metric used (absolute emissions or emissions 

intensity), (2) the geographic scope of the goal (reductions at U.S. or 

worldwide facilities), and (3) the time frame in which the reductions will 

occur. 

First, 19 firms pledged to reduce total emissions, while 18 pledged to 

reduce emissions intensity, and 1 pledged to reduce both total emissions 

and emissions intensity. Of the 19 companies with intensity goals, 15 

measured emissions intensity in terms of their physical units of output 

(such as tons of cement or barrels of beer produced), while the other 4 

firms measured emissions intensity in financial terms (such as dollar of 

revenue.) In addition, EPA expects that many firms that meet their intensity 

goals will also achieve absolute emissions reductions. In fact, EPA 

projected that four of the five firms that were expected to reach their goals 

in 2005 would also achieve absolute emissions reductions, even though 

only one of them has an absolute target. Second, 29 of the 38 companies 
Page 19 GAO-06-97 Climate Change 

established goals relating to their U.S. or North American facilities only, 

while the other 9 established goals relating to their global facilities. Third, 

the time periods covered ranged from 5 to 10 years, and all goal periods 

began in 2000 or later because EPA asked firms to use the most recent data 

available when establishing the base year for their goal. EPA did this to 

prevent firms from counting reductions made prior to joining the program 

and to prevent them from selecting as their baseline a year in which their 

emissions were particularly high, hence making reductions appear steeper 

than they actually were, relative to average conditions.

Reflecting various combinations of the three characteristics, the firms’ 

goals are expressed in different terms. For example, Cinergy Corporation 

pledged to reduce its total domestic greenhouse gas emissions by 5 percent 

from 2000 to 2010, while Miller Brewing Company pledged to reduce its 

domestic greenhouse gas emissions by 18 percent per barrel of production 

(a unit of production intensity goal) from 2001 to 2006, and Pfizer, Inc., 

pledged to reduce its worldwide emissions by 35 percent per dollar of 

revenue (a monetary intensity goal) from 2000 to 2007. Table 2 presents 

information on the 38 firms’ goals.
Page 20 GAO-06-97 Climate Change 

Table 2: Climate Leaders’ Goals as of November 2005

Metric used and percent to be reduced

Geographic scope 

of goal

Company Emissions

Emissions 

intensity

Metric for measuring 

emissions intensity

United 

States Global

Time period 

covered

3M 30 x 2002-07

Advanced Micro Devices, Inc. 40 Manufacturing index x 2002-07

American Electric Power 4 x 2001-06 

Ball Corporation 16 Production index x 2002-12

Bank of America Corporation 9 x 2004-09

Baxter International Inc. 16 Unit of production value x 2000-05

Calpine 4 Megawatt hour x 2003-08

Caterpillar 20 Dollar of revenue x 2002-10

Cinergy Corporation 5 x 2000-10

The Collins Companies 18 x 2000-10

Eastman Kodak Company 10 x 2002-08

Exelon Corporation 8 x 2001-08

First Environment, Inc. Net 0a x by 2008

FPL Group, Inc. 18 Kilowatt hour x 2001-08

Frito-Lay, Inc. 14 Pound of production x 2002-10

GAP, Inc. 11 Square foot x 2003-08

General Electric 1 x 2004-12

General Motors Corporation 10 xb 2000-05

Green Mountain Energy 

Company 

Net 0a x 2005-09

Hasbro, Inc. 30 x 2000-07

Holcim (U.S.) Inc. 12 Ton of cement x 2000-08

IBM Corporationc 10 4 Energy use x Average annual 

reduction

2000-05

Interface, Inc. 15 Unit of production x 2001-10

International Paper 15 x 2000-10

Johnson & Johnson 14 x 2001-10

Marriott International, Inc. 6 Available room x 2004-10

Melaver, Inc. Net 0a x 2006-09

Miller Brewing Company 18 Barrel of production x 2001-06

National Renewable Energy 

Laboratory

10 Square foot x 2000-05

Pfizer, Inc. 35 Dollar of revenue x 2000-07
Page 21 GAO-06-97 Climate Change 

Source: GAO analysis of EPA data.

a

Net zero means that the company will substitute emissions it produces by some other activity such 

that no new, additional emissions are produced. Green Mountain Energy, for example, is substituting 

emissions from fossil fuel-based energy, such as coal or gas, with the purchase of renewable energy 

that produces few greenhouse gas emissions relative to fossil fuels.

b

General Motors pledged to reduce total greenhouse gas emissions from its North American facilities.

c

IBM pledged to achieve a reduction in its average annual carbon dioxide emissions equivalent to 4 

percent of the emissions associated with the company’s worldwide energy use. IBM also pledged to 

reduce its perfluorocarbon emissions from its semiconductor manufacturing processes by 10 percent 

from 2000 to 2005.

DOE and Other Agencies 

Worked with Groups to 

Establish Goals Before 

Joining the Program, and 

Certain Groups’ Goals Were 

Developed for Participation 

in Other Voluntary 

Programs

According to program officials, DOE or another federal agency, such as 

EPA or the U.S. Department of Agriculture (USDA), conducted discussions 

with the industry groups on establishing a goal upon entering the program. 

These officials stated that, since a key element of the program is allowing 

industry groups to take ownership of their goals, DOE and its partner 

agencies generally did not actively negotiate the goals’ specific terms. DOE 

officials told us that the agency remained flexible on goal setting because 

some groups had initiated their own internal emissions reduction programs 

before joining the program or had an existing arrangement with another 

agency, such as EPA. In addition, DOE officials believe it is important for 

the groups to establish goals that meet their unique circumstances. The 

officials told us that they compared the trade groups’ goals with projected 

emissions for their respective industries to gauge their robustness. DOE 

calculates expected conditions for many industrial sectors using EIA data, 

where they are available. (We did not independently review EIA’s data or 

DOE’s analysis of the data.) Further, DOE officials also told us that the 

trade groups have an interest in ensuring that their goals are credible.

PSEG 18 Kilowatt hour x 2000-08

Roche Group US Affiliates 10 x 2001-08

SC Johnson 23 Pound of product x 2000-05

Staples, Inc. 7 x 2001-10

St. Lawrence Cement 15 Ton of product x 2000-10

Sun Microsystems 20 x 2002-12

United Technologies 

Corporation

16 Dollar of revenue x 2001-06

Xerox Corporation 10 x 2002-12

(Continued From Previous Page)

Metric used and percent to be reduced

Geographic scope 

of goal

Company Emissions

Emissions 

intensity

Metric for measuring 

emissions intensity

United 

States Global

Time period 

covered
Page 22 GAO-06-97 Climate Change 

According to a DOE official, participants need not establish a new goal as a 

condition of joining the program, and certain trade groups had already 

initiated internal emissions reduction programs before joining Climate 

VISION or had an existing arrangement with a voluntary program at 

another agency, such as EPA. For example, the nine firms in the aluminum 

industry established a goal of reducing perfluorocarbon emissions by 30 to 

60 percent from a 1990 baseline as part of EPA’s Voluntary Aluminum 

Industrial Partnership. In 2003, as part of Climate VISION, the Aluminum 

Association updated this goal. Similarly, the Semiconductor Industry 

Association’s goal was established in 1999, also in conjunction with an EPA 

program. The International Magnesium Association likewise participates in 

an EPA program but did not establish a quantitative goal for reducing 

emissions until it joined Climate VISION in 2003. 

Fourteen Climate VISION 

Participants Have Set Goals, 

and These Goals Vary

Fourteen groups established quantitative emissions-related goals. More 

specifically, nine pledged to take actions to improve their emissions 

intensity. For example, the American Forest & Paper Association stated 

that it expected to reduce emissions intensity by 12 percent between 2002 

and 2012. Another two groups aimed to reduce emissions of specific 

greenhouse gases. For example, the Semiconductor Industry Association 

pledged to support efforts to reduce PFC emissions by 10 percent over 1995 

levels by 2010. Two more groups established a goal for improving energy 

efficiency. For example, the American Iron and Steel Institute agreed to a 

10 percent, sectorwide increase in energy efficiency by 2012, relative to 

2002. Finally, one industry—the National Mining Association—established 

a goal of both reducing its overall emissions and improving its energy 

efficiency. The Business Roundtable did not set a quantified emissions 

reduction goal, owing to the diversity of its membership. Table 3 outlines 

the type and time frame of industry group goals.
Page 23 GAO-06-97 Climate Change 

Table 3: Climate VISION Trade Groups’ Goals as of November 2005 

Type of goal

Industry/

participant

Reduce 

emissions

Reduce 

emissions 

intensity

Improve 

energy 

efficiency Goal metric

Start and end 

dates

Aluminum

• Aluminum Association

53% Combined direct carbon 

emissions intensity based on 

PFC reductions and reduced 

anode carbon consumption

1990-2010

Automobiles

• Alliance of Automobile 

Manufacturers

10% Carbon dioxide emissions per 

vehicle produced

2002-12

Cement

• Portland Cement 

Association

10% Carbon dioxide emissions per 

ton of cementitious product 

produced or sold

1990-2020

Chemicals

• American Chemistry Council

18%a Greenhouse gas emissions 

intensityb

1990-2012

Electric power

• American Public Power 

Association

The equivalent of

3 to 5%

Ratio of carbon equivalent 

emissions to generation in 

megawatt hours

2002-02 to 

2010-12

• Edison Electric Institute

• Electric Power Supply 

Association

• Large Public Power Council

• National Rural Electric 

Cooperative Association

• Nuclear Energy Institute

• Tennessee Valley Authority

Forest products

• American Forest & Paper 

Association

12% Greenhouse gas intensity 2000-12

Iron and steel

• American Iron and Steel 

Institute

10% Millions of British thermal units 

per ton of steel produced 

2002-12

Lime

• National Lime Association

8% Fuel used per ton of lime 

produced

2002-12

Magnesium

• International Magnesium 

Association 

100% Sulfur hexafluoride emissions by 2010c

Minerals

• Industrial Minerals 

Association North America

4.2% Greenhouse gas emissions from 

fuel combustion

2002-12
Page 24 GAO-06-97 Climate Change 

Source: Climate VISION Web site.

a

According to the American Chemistry Council, the U.S. chemistry industry reduced its greenhouse 

gas intensity by 12 percent from 1990 to 2000, with projections to 2002.

b

The American Chemistry Council measures its greenhouse gas emissions intensity using a special 

index that is particularly suited for an industry with a diverse product base. The index measures 

changes in the physical quantity of production, and where these data are unavailable, the index is 

based on changes in electricity consumption and production worker hours.

c

The International Magnesium Association committed to eliminate all SF6 emissions by 2010 and did 

not define a baseline year because of the nature of its goal.

d

The National Mining Association committed to maintain annual reductions in methane emissions 

achieved since 1990.

e

The National Mining Association committed to maximize efforts to reduce annual carbon reductions 

projected as a result of the partnership with DOE. These projections are 600,000 metric tons of carbon 

equivalent by 2010 and 2 million metric tons by 2015.

As shown in table 3, the majority of the groups’ goals were based on time 

frames that began shortly before the program’s initiation in 2003. 

Specifically, nine groups used 2000 or 2002 as a base year. For example, the 

National Lime Association stated its intention to reduce emissions intensity 

by 8 percent between 2002 and 2012. However, four goals had a base year of 

1995 or earlier. For example, the Portland Cement Association pledged to 

reduce its emissions intensity by 10 percent between 1990 and 2020. DOE 

officials told us that, even though some participants are using 1990 or 

another pre-2003 year as a base year, DOE will count only reductions 

Industry/

participant

Reduce 

emissions

Reduce 

emissions 

intensity

Improve 

energy 

efficiency Goal metric

Start and end 

dates

Mining

• National Mining Association

10% Energy efficiency 2002-12

25 MMTCE Methane emissions in million 

metric tons carbon dioxide 

equivalent per year 

2002-12d

2 MMTCE Million metric tons of carbon 

equivalent

2002-15e

Oil and gas

• American Petroleum 

Institute

10% Energy efficiency 2002-12

Railroads

• American Association of 

Railroads

18% Transportation-related 

greenhouse gas emissions 

intensity adjusted for traffic levels 

in ton miles

2002-12

Semiconductors

• Semiconductor Industry 

Association 

10% PFC emissions in million metric 

tons of carbon equivalent 

1995-2010

(Continued From Previous Page)

Type of goal
Page 25 GAO-06-97 Climate Change 

occurring between 2002 and 2012 as part of the program’s contribution 

toward the President’s 18 percent emissions intensity reduction goal. 

In addition to setting emissions-related goals, some groups also set other 

kinds of goals. For example, the American Petroleum Institute committed 

to 100 percent member participation in EPA’s voluntary Natural Gas STAR 

program (which helps U.S. natural gas companies adopt technologies and 

practices to reduce emissions of methane) and DOE’s Combined Heat and 

Power Program (which works to eliminate barriers to the adoption of 

combined heat and power technology systems.) Similarly, the Business 

Roundtable established a goal of 100 percent member participation in 

voluntary actions to reduce, avoid, offset, and sequester greenhouse gas 

emissions. 

Many Climate VISION 

Participants Said Goals May 

Be Difficult to Achieve 

without Reciprocal Federal 

Actions

Although all Climate VISION participants established goals, a majority of 

the groups qualified their participation by stating that their ability to meet 

their goals would depend on some reciprocal government action. This 

includes 9 of the 14 groups with a quantitative goal as well as 5 of the 7 

electric power groups. For example, the American Chemistry Council 

stated that “it will be difficult, if not impossible, for the chemical industry 

to do its share to reach the President’s goal of reducing emissions intensity” 

without an aggressive government role in removing barriers to progress 

and providing incentives, such as tax code incentives. Similarly, the 

American Petroleum Institute stated that “future progress will be 

particularly difficult because of the increased energy and capital 

requirements at refineries due to significant tightening of gasoline and 

diesel fuel specifications in the coming decade.” The group said it would 

look to the administration “to aggressively work to eliminate any potential 

regulatory barriers to progress in these areas.” Likewise, the Association of 

American Railroads stated that the industry’s efforts will depend upon 

DOE’s continued funding of a government/rail industry cooperative venture 

to improve railroad fuel efficiency. Appendix III lists the reciprocal federal 

actions outlined in participants’ statements.
Page 26 GAO-06-97 Climate Change 

Both Agencies Have 

Estimated Their 

Programs’ Coverage 

and Are Working to 

Estimate Their Impact, 

but It Will Be Difficult 

to Determine Specific 

Emissions Reductions 

from Each Program

EPA and DOE both estimated the share of U.S. greenhouse emissions 

attributable to their participants. Both agencies are also working to 

estimate the effect of their programs on reducing emissions, and they 

expect the estimates to be completed in 2006. Preparing such estimates will 

be challenging because there is considerable overlap between these two 

programs and other voluntary programs.

Both Agencies Estimated 

the Share of U.S. Emissions 

Generated by Current 

Program Participants

EPA estimated in 2005 that participating firms accounted for at least 8 

percent of U.S. emissions on average for the years 2000 through 2003. EPA 

based this estimate on emissions data from the first 50 program 

participants and believes the estimate is conservative, in part, because (1) 

it does not reflect data from the other 24 participating firms and (2) it does 

not include all types of emissions from each firm. For example, the 

estimate does not include indirect emissions (such as emissions from the 

use of purchased electricity or steam) or what EPA refers to as “optional” 

emissions, such as employee commuting and employee business travel.

Because the electric utility sector accounts for about one-third of U.S. 

greenhouse emissions, we used an EPA database to determine the share of 

greenhouse gas emissions produced by Climate Leaders firms12 in that 

sector. As shown in table 4, we found that participating firms accounted for 

nearly 18 percent of carbon dioxide emissions from U.S. electricity 

generation (i.e., power plants only) in 2000 (latest available data), or about 

6 percent of total U.S. emissions.

12We used EPA’s e-GRID database, which represents emissions from U.S. power plants 

greater than a megawatt in size. EPA estimates that the database captures 90 to 95 percent 

of U.S. carbon dioxide emissions from the generation of electric power in 2000. 
Page 27 GAO-06-97 Climate Change 

Table 4: Climate Leaders’ Carbon Dioxide Emissions from Electricity Generation 

(i.e., Power Plants Only), 2000a

Source: GAO analysis of EPA data.

a

Emissions data are for the year 2000 but have been updated to reflect corporate structures as of 

December 2002.

b

Less than 0.05 percent.

c

The “100 percent” refers only to those power plant emissions captured by the e-GRID database, about 

90 to 95 percent of the U.S. total. 

EPA program managers said they have set a participation goal of 200 firms 

by 2012, and EPA is almost on track to meet this goal. However, a program 

manager told us that EPA has not tried to estimate the share of U.S. 

emissions that the 200 firms might account for because it is difficult to 

predict with any accuracy the size and types of firms that may join the 

program in the future and the firms’ emissions reduction goals.

Climate Leaders program staff, with assistance from contractors, recruit 

new participants through various means. For example, they attend industry 

sector meetings and corporate environmental meetings as well as meetings 

of participants in other EPA programs, such as Energy STAR. In addition, 

EPA publishes public service announcements in trade and industry 

journals.

According to DOE, the thousands of individual companies that are 

members of the participating trade groups (not including Business 

Climate Leaders firms

Carbon dioxide 

emissions (millions of 

tons) 

Percent of U.S. 

carbon dioxide 

emissions 

American Electric Power 225.9 8.5%

Calpine Corporation 4.2 0.2%

Cinergy Corporation 66.8 2.5%

Entergy Corporation 50.8 1.9%

Exelon Corporation 16.7 0.6%

FPL Group, Inc. 45.0 1.7%

Green Mountain Energy Company 0.07 b

Nisource Inc. 20.0 0.8%

PSEG 18.2 0.7%

We Energies 26.0 1.0%

Total - Climate Leaders 473.7 17.9%

Total - U.S. electricity generation 2,652.9 100%c
Page 28 GAO-06-97 Climate Change 

Roundtable members) contribute over 40 percent of total U.S. greenhouse 

gas emissions. DOE officials told us they believe this estimate, based 

largely on EIA and EPA data, is conservative, because the utility sector 

alone accounts for one-third of U.S. greenhouse gas emissions. (We did not 

independently review EIA’s or EPA’s data or the estimate based on these 

data.)

DOE officials told us that they regularly seek to recruit new members and 

expect at least one more trade group to join the program, but they do not 

have a specific goal for the number of new participants expected to join. 

DOE also does not have a goal for the share of U.S. emissions contributed 

by future participants. 

While Both Agencies Are 

Working to Estimate 

Program Impacts, It Will Be 

Challenging to Determine 

Specific Emissions 

Reductions Attributable to 

Each Program

EPA and DOE are working, as part of an interagency program, to estimate 

their programs’ effect on reducing U.S. greenhouse gas emissions. Agency 

officials said that the estimates would be completed in 2006, in fulfillment 

of a U.S. commitment under the 1992 Framework Convention on Climate 

Change. (Under the Convention, the United States committed to report 

periodically on policies and measures undertaken to reduce greenhouse 

gas emissions.)

In 2005, EPA estimated that participating firms’ actions were reducing U.S. 

emissions by 8 MMTCE a year. This amount is equivalent to the annual 

emissions of 5 million automobiles and represents less than one-half of 1 

percent of U.S. emissions in 2003 (the latest year for which data are 

available.) EPA derived this estimate by adding up the average annual 

expected emissions reductions for the first 35 firms that had set goals. 

(Three other firms set goals later.) However, EPA officials cautioned that 

this figure does not represent an official estimate of emissions reductions 

attributable to the program because many Climate Leaders firms 

participate in other voluntary programs to which their emissions 

reductions may be credited.

A DOE official said that, to determine the emissions reductions attributable 

to the Climate VISION program, DOE will compare participating trade 

groups’ reported emissions with comparable EIA projections for the time 

period. If the trade group comprises an entire industry, DOE will use the 

EIA projection for the entire industry; if the trade group comprises less 

than the entire industry, DOE will prorate the industry total based on the 

trade group’s share of the industry.
Page 29 GAO-06-97 Climate Change 

Estimating the effect of the two programs, as opposed to other voluntary 

programs and other factors, will be challenging for two reasons. First, 

because the firms and trade groups participating in these two programs 

may also participate in other voluntary programs, it will be difficult to 

determine the two programs’ effect on reducing emissions, as opposed to 

other programs’ effects on reducing emissions. Unless EPA and DOE find 

an effective way to disaggregate the emissions reductions attributable to 

each program, there is the possibility that total emission reductions from 

voluntary federal programs will be overstated because the same emissions 

reductions reported by organizations participating in Climate Leaders, 

Climate VISION, and other programs will be counted by more than one 

program. EPA officials told us that they recognize the challenge of 

attributing the effects of the various voluntary programs and stated that 

they are trying to avoid double counting of the programs’ results. Second, 

the reductions in a participants’ emissions that are due to a program are the 

difference between its actual emissions generated during a period of time 

and the amount of emissions that it would have generated for that period if 

it were not participating in the program. Although a participant can 

estimate its future emissions based on its estimate of future conditions 

(e.g., energy prices and other factors), all of these conditions may change 

during the time period. Any such change would need to be assessed to 

determine how it might have affected the participant’s emissions.

There are three types of overlap involving the firms and trade groups 

participating in Climate Leaders and Climate VISION. First, as of November 

2005, most Climate Leaders firms also participate in other voluntary EPA 

programs. Specifically, 60 of the 74 firms took part in one or more other 

programs, while the other 14 firms did not take part in any other programs, 

as shown in figure 2. Of the 60 firms, 36 took part in one to three other 

voluntary climate programs. For example, Calpine participated in three 

programs, including the Combined Heat and Power Partnership, and 

Natural Gas STAR. Another 18 firms participate in four to six other 

programs. For example, Cinergy Corporation participated in EPA’s Coalbed 

Methane Outreach Program, Combined Heat and Power Partnership, and 

Natural Gas STAR, among others. Additionally, six firms participate in 

seven or more programs. IBM, for example, participates in 11 other 

programs, including Energy STAR and the PFC Emissions Reduction 

Partnership for the Semiconductor Industry.
Page 30 GAO-06-97 Climate Change 

Figure 2: Climate Leaders Members’ Participation in Other EPA-Sponsored 

Voluntary Programs, as of November 2005

Second, some firms participating in Climate Leaders are members of trade 

groups participating in Climate VISION. We identified such firms in the 

automobile manufacturing, cement, electric power, and paper industries. 

For example, General Motors, a Climate Leaders participant, is a member 

of the Alliance of Automobile Manufacturers, a Climate VISION participant. 

Finally, three of the Climate VISION trade groups also participate in EPA 

voluntary programs. Specifically, the Aluminum, Magnesium, and 

Semiconductor Associations also participate in industry-focused EPA 

programs. Further, the Aluminum and Semiconductor Associations 

previously developed their goals in conjunction with other EPA voluntary 

programs. 

The fact that there is overlap among the organizations participating in both 

Climate Leaders and Climate VISION, and among participants in these 

programs and other federal voluntary programs, creates the possibility that 

their emissions reductions will be counted more than once. For example, 

the emissions reductions claimed by firms participating in Climate Leaders 

who are also members of trade groups participating in Climate VISION may 

0

5

10

15

20

25

30

35

40

7 or

more

0 1--3 4--6

Participants

Number of programs

Source: GAO analysis of EPA data.

14

36

18

6
Page 31 GAO-06-97 Climate Change 

be counted twice—the individual firm’s achievement may be credited 

under the Climate Leaders program, while the same achievement may be 

counted toward the trade group achieving its goal under Climate VISION. 

Further, for those trade groups that participate in Climate VISION and 

other EPA voluntary programs, it is possible that the same actions and the 

same emissions reductions will be counted by both programs. If 

participants’ emissions reductions are counted by multiple programs, it is 

possible that any attempt to estimate the overall impact of voluntary 

federal climate change programs on greenhouse gas emissions will be 

overstated.

In addition, it will be challenging to accurately estimate the programs’ 

effects because it is difficult to determine the level of emissions for a firm 

or trade group in the absence of these programs and other factors. For 

example, increases in energy prices can be expected to reduce energy 

consumption, which is significant because carbon dioxide emissions from 

energy use account for more than 80 percent of U.S. emissions. According 

to EIA’s 2002 estimate, which was reflected in the President’s February 

2002 plan, U.S. emissions intensity was projected to improve 14 percent by 

2012. However, according to EIA’s 2006 estimate, largely because of an 

increase in energy prices, emissions intensity is now projected to improve 

17 percent over the same period. If participants had anticipated such an 

improvement, they might have projected lower emissions over time. This 

means that the difference between their reported emissions and their 

projected emissions would be smaller, which would decrease the emissions 

reductions attributable to participation in a voluntary program.

Conclusions The administration has chosen to pursue voluntary rather than mandatory 

activities to reduce greenhouse gas emissions. Given the potential gravity 

of the climate change problem, programs such as Climate Leaders and 

Climate VISION will need to be especially robust and involve a substantial 

portion of the economy if they are going to achieve the desired results. To 

date, according to EPA and DOE estimates, these two voluntary programs 

involve companies and industries representing less than one-half of total 

U.S. emissions, which immediately limits their potential impact. This 

makes it all the more important that the voluntary programs maximize the 

extent to which their potential is achieved.

To this end, we found that opportunities remain to improve the 

management of both programs. First, while many participants appear to 

have made considerable progress in completing program steps in a timely 
Page 32 GAO-06-97 Climate Change 

manner, some participants in both programs appear not to be progressing 

at the rate expected by the sponsoring agencies. For example, although 

EPA expects that firms will generally take about 2 years to establish their 

emissions reduction goals, of the 51 firms that joined in 2002 and 2003, the 

first 2 years of the program, 18 firms had not done so as of November 2005.

Second, while 12 of these 18 firms are currently negotiating their goals with 

EPA, 6 others had not begun negotiations because their inventories had not 

been finalized. Similarly, although DOE expects that groups will generally 

complete their work plans within about a year of joining the program, of 

the 13 groups that joined during 2003, the program’s first year, 2 had not 

completed their plans as of November 2005. EPA is developing a system for 

tracking firms’ progress in completing key steps under Climate Leaders, 

but DOE does not have a system for tracking trade group’s progress under 

Climate VISION. We believe that, without a system to track how long 

participants take to complete key program steps, DOE cannot ensure that 

the program’s goals are being accomplished. Moreover, neither agency has 

a written policy on what action to take when a firm is not making sufficient 

progress in setting goals and completing other key program steps. We 

believe that, by establishing written policies regarding consequences for 

not completing these steps on schedule, the agencies could more easily 

ensure participants' active involvement in the programs, thereby increasing 

the opportunities for contributing to the President’s emissions intensity 

reduction goal.

Both agencies are working this year to estimate the emissions reductions 

attributable to their programs. No matter how many firms and trade groups 

have joined the programs and how well they are meeting program 

expectations, to demonstrate the value of voluntary programs—as opposed 

to mandatory reductions—the agencies will need robust estimates of the 

programs’ effect on reducing emissions. However, as we noted, making this 

estimate will be challenging for two reasons. First, the overlaps between 

organizations participating in these two programs and other voluntary 

programs make it difficult to attribute specific emissions reductions to one 

program. EPA and DOE will need to find a way to determine the emissions 

reductions attributable to each program so that the same emissions 

reductions reported by organizations participating in Climate Leaders, 

Climate VISION, and other voluntary programs are not counted by more 

than one program. Otherwise, estimates of total emission reductions from 

voluntary federal programs could be overstated. Second, it will be difficult 

to determine the emissions reductions stemming from participants’ 

involvement in the program, as opposed to higher energy prices or other 

factors, because it is difficult to determine what participants’ emissions 
Page 33 GAO-06-97 Climate Change 

would be in the absence of these programs. It will therefore be difficult to 

evaluate the merits of these voluntary programs. Nevertheless, it will be 

important for the agencies to overcome these challenges in determining 

their programs’ emission reduction contributions. 

Recommendations To ensure that the Congress and the public have information with which to 

evaluate the effectiveness of these voluntary programs and to increase the 

opportunities for contributing to the President’s emissions intensity 

reduction goal, we are recommending that DOE develop a system for 

tracking participants’ progress in completing key steps associated with the 

program. We are also recommending that both EPA and DOE develop 

written policies establishing the consequences for not completing program 

steps on schedule. 

Agency Comments and 

Our Evaluation

We provided a draft of this report to EPA and DOE for their review and 

comment. EPA did not comment on our recommendation, but rather 

provided a summary of the program’s accomplishments, noting that 85 

firms now participate in Climate Leaders and that 5 firms had met their 

emissions reduction goals (see app. IV). DOE stated that, overall, the draft 

report provided a useful overview of the Climate VISION program and 

agreed with our recommendation regarding a tracking system and said it 

will consider our recommendation regarding establishing a written policy 

(see app. V). However, DOE stated that the Climate VISION Web page 

contains a wealth of information on the program, which may be sufficient 

to ensure the active involvement of participating groups. Because DOE’s 

Web site does not contain information regarding the expected time frames 

for completing key program steps or the consequences for groups not 

meeting the agency’s expectations, we continue to believe that DOE should 

establish a written policy regarding what actions it will take when a trade 

group is not making sufficient progress in completing key steps. Although 

DOE agreed with our statement that Climate VISION participants account 

for at least 40 percent of total U.S. greenhouse gas emissions, it noted that 

the program covers about four-fifths of total U.S. industrial- and 

power-related greenhouse gas emissions, which makes the potential impact 

of the program substantial. Also, although DOE agreed that higher energy 

prices may lead to lower emissions overall, it noted that, in the power 

sector, higher energy prices may lead to greater emissions. This can occur 

if electric power producers use less oil or natural gas (which produce fewer 

emissions per unit of electricity) and more coal (which produces more 
Page 34 GAO-06-97 Climate Change 

emissions, relative to oil or natural gas). Both EPA and DOE provided 

technical comments, which we have incorporated in this report as 

appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution of this report until 30 

days after the date of this letter. At that time, we will send copies to the 

Secretary of Energy; the Administrator, EPA; and other interested officials. 

The report will also be available on GAO's home page at 

http://www.gao.gov. 

If you have questions concerning this report, please contact me at (202) 

512-3841 or stephensonj@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix VI.

John B. Stephenson

Director, Natural Resources and

 Environment
Page 35 GAO-06-97 Climate Change 

Appendix I

U.S. Government Voluntary Climate Change Apendxies

Programs ApendxiI

In addition to Climate Leaders and Climate VISION, the U.S. government 

supports numerous other voluntary programs that encourage participants 

to reduce their greenhouse gas emissions, as shown in the following table, 

arranged alphabetically by sector. For the purposes of this report, we 

define voluntary greenhouse programs as those programs that

• do not involve regulation, government-sponsored research and 

development, tax incentives, financial assistance, or 

government/industry cost-sharing components; 

• were created for the specific purpose of reducing greenhouse gases or 

were created to reduce other pollutants but had the additional benefit of 

reducing greenhouse gases; and

• involve only dissemination of information to nonfederal parties. 

Table 5: Other U.S. Voluntary Greenhouse Gas Emissions Reduction Programs

Sector/Program

Affected 

greenhouse 

gases 

Implementing 

agencies Purpose 

Energy: commercial, and residential

Emerging Technologies Carbon dioxide DOE Increase demand for, and bring new, highly efficient 

technologies to market for buyers, while assisting 

manufacturers, energy service companies, and utilities. The 

focus is on highly energy-efficient products for commercial and 

residential building applications.

Energy STAR for the 

Commercial Market

Carbon dioxide EPA Promote strategies for strong energy management by engaging 

top company leadership, promoting standardized measurement 

tools to assess performance of buildings, and providing 

information on best practices in energy efficiency.

Energy STAR - Labeled 

Products

Carbon dioxide EPA/DOE Provide information to consumers and homeowners so that 

they can make sound investments when buying a new home or 

when undertaking a home improvement project.

Energy STAR for the 

Residential Market

Carbon dioxide EPA Provide guidance for homeowners on designing efficiency into 

kitchen, additions, and whole-home improvement projects and 

work with major retailers and other organizations to help 

educate the public.

Federal Energy Management 

Program (FEMP)

Carbon dioxide, 

methane, nitrous 

oxide

DOE Promote energy efficiency and renewable energy use in federal 

buildings, facilities, and operations.

Voluntary Reporting of 

Greenhouse Gases Programa

All DOE Record the results of voluntary measures undertaken by 

companies and other organizations to reduce, avoid, or 

sequester greenhouse gas emissions.
Appendix I

U.S. Government Voluntary Climate Change 

Programs

Page 36 GAO-06-97 Climate Change 

Energy: Industrial

Best Practices Program Carbon dioxide, 

methane, nitrous 

oxide

DOE Offer industry tools to improve plant energy efficiency, enhance 

environmental performance, and increase productivity.

Energy STAR for Industry 

(formerly Climate Wise)

Carbon dioxide EPA Enable industrial companies to evaluate and cost-effectively 

reduce their energy use through established energy 

performance benchmarks, strategies for improving energy 

performance, technical assistance, and recognition for 

accomplishing reductions in energy.

Industrial Assessment Centers Carbon dioxide DOE Provide no-cost energy assessments to small- and mediumsized manufacturers to help identify opportunities to improve 

productivity, reduce waste, and save energy.

Transportation

Best Workplaces for 

Commuters 

Carbon dioxide, 

methane, nitrous 

oxide

EPA and 

Department of 

Transportation

Advocate employer-provided commuter benefits and highlight 

the efforts of employers to help get employees to work safely, 

on time, and free of commuter-related stress.

Clean Cities Carbon dioxide, 

methane, nitrous 

oxide

DOE Advance the Nation’s economic, environmental, and energy 

security by supporting local decisions to adopt practices that 

contribute to the reduction of petroleum consumption.

SmartWay Transport 

Partnership

Carbon dioxide EPA Reduce emissions from the freight sector by creating 

partnerships in which partners commit to measure and improve 

the efficiency of their freight operations using EPA-developed 

tools, reducing unnecessary engine idling, and increasing the 

efficiency and use of rail and intermodal operations.

Industry/Agriculture

AgSTAR Methane EPA and 

Department of 

Agriculture

Reduce emissions from livestock waste management 

operations by promoting the use of biogas recovery systems.

Coalbed Methane Outreach 

Program

Methane EPA Reduce emissions by promoting the profitable recovery and use 

of coal mine methane by coal mining and other types of 

companies.

High GWP Environmental 

Stewardship Initiativeb

High GWP 

gases

EPA Aim to limit emissions of HFCs, PFCs, and SF6 in several 

industrial applications: semiconductor production, refrigeration, 

electric power distribution, magnesium production, and mobile 

air conditioning.

Natural Gas STAR Methane EPA Reduce emissions from U.S. natural gas systems through the 

widespread adoption of industry best management practices.

(Continued From Previous Page)

Sector/Program

Affected 

greenhouse 

gases 

Implementing 

agencies Purpose 
Appendix I

U.S. Government Voluntary Climate Change 

Programs

Page 37 GAO-06-97 Climate Change 

Sources: U.S. Department of State, U.S. Climate Action Report 2002; DOE Web site, EPA Web site. Selection of programs is based on a 

list of current U.S. climate policies and measures provided by EPA.

a

This initiative cuts across all sectors and greenhouse gas emissions sources. However, for the sake 

of simplicity, we list it here under commercial and residential energy.

b

This initiative consists of six separate programs: the Voluntary Aluminum Industrial Partnership, the 

HFC-23 Emission Reduction Program, the PFC/Climate Partnership in the Semiconductor Industry, 

the SF6 Emissions Reduction Partnership for Electric Power Systems, the SF6 Emission Reduction 

Partnership for the Magnesium Industry, and the Mobile Air Conditioning Climate Protection 

Partnership. 

Waste Management

Landfill Methane Outreach 

Program

Methane EPA Promote the use of landfill methane gas as a renewable, green 

energy source. The program’s focus is on smaller landfills not 

regulated by EPA’s New Source Performance Standards and 

Emissions Guidelines.

Climate Change and Waste 

Program

All EPA Encourage recycling and waste reduction for the purpose of 

reducing greenhouse gas emissions. Provide technical 

assistance for waste prevention, recycling, and buying recycled 

products.

Other

Clean Energy-Environment 

State Partnership Program

Carbon dioxide, 

methane, nitrous 

oxide

EPA Encourage states to develop and implement a comprehensive 

strategy for using new and existing energy policies and 

programs to promote energy efficiency, renewable energy, and 

other clean energy sources.

State and Local Climate 

Change Outreach Program

Carbon dioxide, 

methane nitrous 

oxide 

EPA Enable state and local decision makers to incorporate climate 

change planning into their priority planning to help them 

maintain and improve their economic and environment assets.

(Continued From Previous Page)

Sector/Program

Affected 

greenhouse 

gases 

Implementing 

agencies Purpose 
Page 38 GAO-06-97 Climate Change 

Appendix II

Scope and Methodology ApendxiI

To determine the steps participants are expected to complete under each 

program and the expected time frames for completion, we reviewed agency 

documents, where available, and interviewed agency officials within the 

Environmental Protection Agency’s (EPA) Office of Air and Radiation and 

the Department of Energy’s (DOE) Office of Policy and International 

Affairs. We also obtained energy and emissions intensity data from Energy 

Information Administration (EIA) staff. To ascertain the extent to which 

agency officials assist participants in setting emissions reduction goals and 

the types of goals established, we reviewed agency documents and 

interviewed agency officials. We also reviewed commitment letters sent to 

DOE by the various trade groups, since each group prepared individualized 

letters, but we did not review the paperwork submitted by Climate Leaders 

participants to EPA, since each firm signed a standardized membership 

agreement with EPA. 

To determine the extent to which participants’ reductions are reported in 

each program, we reviewed agency guidance on reporting and verification 

and interviewed agency officials. In addition, we reviewed the 

recommended reporting protocols for each program, including EPA’s 

Design Principles, which is EPA’s emissions reporting guidance, and DOE’s 

Draft Technical Guidelines for Voluntary Reporting of Greenhouse Gases 

Program. We also reviewed EPA’s annual greenhouse gas inventory 

summary and goal tracking form, the Inventory Management Plan (IMP) 

desktop review form, the on-site IMP review facility selection form, and the 

IMP on-site review form.

To determine how EPA quantified the share of U.S. greenhouse gas 

emissions covered by Climate Leaders and the total reductions expected 

from the program, we interviewed EPA staff. To assess the size of the 

electricity generating sector participating in Climate Leaders, we used 

EPA’s e-GRID database, which contains information on the environmental 

characteristics of almost all electric power generated in the United States. 

To ascertain how DOE quantified its estimate of Climate VISION coverage, 

we reviewed DOE documents and interviewed DOE staff. To determine the 

agencies’ plans for future coverage and impact, we reviewed performance 

plans and an annual report (for EPA) and interviewed agency officials for 

both agencies. To assess the reliability of the EPA, DOE, and other data, we 

talked with agency officials about data quality control procedures and 

reviewed relevant documentation. We determined the data were 

sufficiently reliable for the purposes of this report. 
Appendix II

Scope and Methodology

Page 39 GAO-06-97 Climate Change 

To ascertain how many firms participating in Climate Leaders also 

participate in other EPA voluntary climate programs, we cross-referenced a 

Climate Leaders roster against EPA lists of membership in other EPA 

voluntary programs. Similarly, we reviewed membership in DOE’s Climate 

VISION program and cross-referenced selected individual trade group 

members with the list of Climate Leaders members. 

Finally, to create a list of other government-sponsored, voluntary 

greenhouse gas emissions reduction programs, we requested information 

from EPA on all current U.S. policies and measures designed to reduce 

greenhouse gas emissions. We narrowed the list to those programs that 

were voluntary. We defined voluntary programs to include only those 

programs in which private sector parties agree, of their own free will, to 

reduce greenhouse gas emissions. Therefore, we excluded regulatory 

programs. We also excluded programs consisting primarily of research and 

development, tax incentive, or financial assistance, and 

government/industry cost share arrangements. However, we determined 

that voluntary programs can include programs in which the government 

provides information to private sector parties, individuals, or state and 

local governments. We also included programs that were created both for 

the specific purpose of reducing greenhouse gas emissions and that were 

created to reduce other pollutants but have as a side benefit the reduction 

of greenhouse gases. We included programs that are supported by the 

Departments of Agriculture, Energy, and Transportation, as well as EPA. 

We conducted our review from June 2004 through March 2006 in 

accordance with generally accepted government auditing standards.
Page 40 GAO-06-97 Climate Change 

Appendix III

Climate VISION Participant Qualifying 

Statements ApendxiI

Industry group Qualifying statement

Alliance of Automobile 

Manufacturers

“Clearly, achievement of this commitment and the national goal will depend on a number of external factors, 

including economic stability, coordinated regulatory policies that avoid mandates and other market barriers, 

weather variations which skew energy use, and support from the utilities’ energy mix, including emission factors 

reductions.”

Aluminum Association No qualifying statement noted.

American Chemistry 

Council

“ . . . government can help by removing barriers that impede efficiency upgrades and by providing incentives for 

companies to implement state-of-the-art technology. Without an aggressive government role in removing 

barriers to progress and providing incentives, it will be difficult, if not impossible, for the business of chemistry to 

do its share to reach the president’s goal of reducing national greenhouse gas intensity by 18 percent during the 

2002-2012 timeframe.”

American Forest & 

Paper Association

“As an organization, we believe that our success will depend in part on the Administration’s efforts to rationalize 

and manage the activities of all government agencies, especially with respect to the promulgation of regulatory 

requirements that may result in increases in greenhouse gas emissions. Our commitment also will naturally 

depend on the parameters of any implementation guidelines that may be developed. Specifically, we strongly 

encourage the Administration to address regulatory requirements where the negative climate impacts outweigh 

any environmental benefits.”

American Iron and 

Steel Institute

“We propose to use the [2001 DOE Steel Industry] Roadmap goals as a basis for addressing the President’s 

Business Challenge. The Roadmap goals, however, are expressed in terms of technical feasibility and are 

qualified by the fact that the cost of acquiring and implementing any new technology must be economically 

justifiable for it to achieve widespread adoption in the industry.”

American Petroleum 

Institute 

“Future progress will be particularly difficult because of the increased energy and capital requirements at 

refineries due to significant tightening of gasoline and diesel fuel specifications in the coming decade. As part of 

this program, API will look to the Administration to aggressively work to eliminate any potential regulatory 

barriers to progress in these areas.”

Association of 

American Railroads

“Most recently we have embarked on a cooperative venture with DOE’s Office of Energy Efficiency and 

Renewable Energy to explore methods of improving railroad fuel efficiency. . . The industry’s efforts, of course, 

will also depend upon DOE’s funding the above-described government/rail industry cooperative venture to 

improve railroad fuel efficiency as DOE had previously indicated it was prepared to do. . . We concur with DOE 

that industry expertise and in-kind contributions—coupled with federal government funding and the resources of 

DOE’s national laboratories—are necessary for an effective program to be planned and executed.”

Business Roundtable No qualifying statement noted.

Industrial Minerals 

Association – North 

America

“We encourage the Administration to do all that it can to support the domestic soda ash, borates, and sodium 

silicates industries, not only because they contribute significantly to the U.S. economy, but also because they are 

more protective of the environment than their competitors outside the U.S. Shifts in production to the U.S. from 

offshore producers of soda ashes, borates, and sodium silicates would decrease the world’s production of 

greenhouse gases.”

Magnesium Industry No qualifying statement noted.
Appendix III

Climate VISION Participant Qualifying 

Statements

Page 41 GAO-06-97 Climate Change 

Source: Information from DOE’s Web site.

National Lime 

Association

“There is much that the government can do to address regulatory barriers that inhibit progress towards these 

goals, as well as to support voluntary efforts by the lime industry . . . In particular, we encourage the 

Administration to rationalize and manage the implementation of regulations that impede the permitting of 

projects to improve the efficiency and environmental performance of lime manufacturing operations.” (Attached 

is a list of specific activities that will enhance the ability of the Lime Association to meet its Climate VISION 

goals. These activities include regulatory streamlining, government assistance in obtaining permits to use 

alternative fuels; tax code improvements in two areas; funding assistance for small businesses; assistance in 

persuading some lime customers to accept changes in product characteristics resulting from GHG intensity 

reductions; and assurance that domestic companies do not lose market share to foreign industries).

National Mining 

Association

No qualifying statement noted.

Portland Cement 

Association

No qualifying statement noted.

Power Partners 

(electric power sector)

Some of the seven members of the Power Partners coalition included, in their individual commitment letters, 

expectations of the federal government. For example: 

• The American Public Power Association and the Large Public Power Council joint letter states that, “Full 

realization [of hydropower potential] hinges on achieving targeted reforms to the current Federal Energy 

Regulatory Commission (FERC) regulatory process.”. . . and “ Although estimates vary, opportunities exist to 

improve the generation efficiency of existing coal-fired capacity by 4 to 8 percent. . . Our ability to implement 

such energy efficiency projects will hinge on removal of regulatory barriers to such projects under the Clean Air 

Act.”

• The Edison Electric Institute (EEI) states that, “A combination of power sector and government efforts will be 

necessary, including . . . government laws, regulations, and policies favoring the full utilization or maintenance 

of nuclear and hydroelectric plant generating capacity; adequate supplies and delivery infrastructure for natural 

gas; economic incentives for renewables; and the full benefits of energy efficiency and DSM, as well as offset 

projects.” Attached to the letter is a list of specific government policies that would help EEI meet its goals. 

These policies include, among other things, hydroelectric licensing reform, nuclear power plant licensing 

extensions, reform of New Source Review regulations under the Clean Air Act, transmission siting authority for 

the federal government, and tax policies, such as accelerated depreciation and amortization of pollution control 

equipment and tax credits for renewable energy.

• The Electric Power Supply Association states that, “EPSA member companies are committed to utilizing this 

generation capacity to the fullest extent possible and will work diligently to develop and maximize electricity 

production for clean energy sources to levels that are necessary to achieving the greenhouse gas intensity 

goals outlined above. The ability of our members to realize these industry goals is tied to the advancement of 

policies for promoting competitive markets for electricity. Specifically, it depends on actions and policies to 

expand wholesale electric competition and rationalize regulations, such as Federal Energy Regulatory 

Commission’s standard electric market design and Regional Transmission Organization initiatives; advance 

market-based multi-emissions legislation; streamline current regulatory programs, and seek better disclosure 

and market transparency.”

• The Nuclear Energy Institute states that, “The nation’s ability to realize the promise of nuclear energy after 

2012 will depend on actions and policies we undertake in the next one to two years, particularly new policy 

initiatives designed to stimulate investment in technologies that require large capital investments and long lead 

times.”

Semiconductor 

Industry Association 

As part of the SIA Memorandum of Understanding with EPA, EPA’s responsibilities include: (1) participating in 

and supporting conferences to share information on emission reduction technologies; (2) addressing regulatory 

barriers that may impede voluntary, worldwide emission reduction strategies; (3) recognizing SIA and the 

participating companies for their emission reduction commitment, technical leadership, and achievements over 

time.

(Continued From Previous Page)

Industry group Qualifying statement
Page 42 GAO-06-97 Climate Change 

Appendix IV

Comments from Environmental Protection 

Agency ApendxiIV
Page 43 GAO-06-97 Climate Change 

Appendix V

Comments from the Department of Energy ApendxiV
Appendix V

Comments from the Department of Energy

Page 44 GAO-06-97 Climate Change 
Appendix V

Comments from the Department of Energy

Page 45 GAO-06-97 Climate Change 
Page 46 GAO-06-97 Climate Change 

Appendix VI

GAO Contact and Staff Acknowledgments ApendxiVI

GAO contact John Stephenson (202) 512-3841 or stephensonj@gao.gov

Acknowledgments In addition to the contact named above, David Marwick, Assistant Director; 

John Delicath; Anne K. Johnson; Chester Joy; Micah McMillan; and Joseph 

D. Thompson were the major contributors to this report. Kisha Clark, 

Heather Holsinger, Karen Keegan, Jean McSween, Bill Roach, and Amy 

Webbink also made important contributions. 

(360529)
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