Thursday, April 1, 2010

Sign-on Letter to US EPA to Add Products and Packaging to US Greenhouse Gas Inventory

EPA has published a draft update of the US Greenhouse Gas Inventory (1990 – 2008).

This is a great opportunity for your voice to make a difference and get systems/ consumption-based greenhouse gas emissions added to the US Inventory! Please encourage US EPA to include products and packaging in the US Greenhouse Gas Inventory.

Sign on at

To view the draft Inventory, go to

April 8, 2010

Mr. Leif Hockstad
Environmental Protection Agency
Climate Change Division (6207J)
1200 Pennsylvania Ave., NW
Washington, DC 20460

Dear Mr. Hockstad:

We appreciate the opportunity to comment on the Draft US Greenhouse Gas Inventory.

We believe that a major opportunity is overlooked in the Draft Inventory – an opportunity that EPA itself highlighted in the path-breaking report released in September 2009, Opportunities to Reduce Greenhouse gas Emissions through Materials and Land Management Practices. The report viewed greenhouse gas data from a systems-based perspective, which sums all the greenhouse gas impacts “embodied” in goods and materials – from resource extraction, manufacturing, and transport to final disposal. The EPA report showed that production, transport, use and disposal of goods and materials contributes 37 percent to the nation’s GHG inventory. That’s more than building energy consumption, passenger transportation or food.

The global impact of US consumption of goods and materials is even greater. A supplemental white paper released simultaneously by the Product Policy Institute, Products, Packaging and US Greenhouse Gas Emissions, shows that when emissions from products made abroad and consumed here are included, and exports are subtracted, the number rises to 44 percent. When viewed from the perspective of consumption, the greenhouse gas impact of the US is higher than suggested by the traditional IPCC accounting standard. This is of great importance: consumption is the root cause of emissions, and failure to at least acknowledge the impacts of consumption exposes EPA to unnecessary criticism that the US Inventory is providing an incomplete picture of how the nation contributes to emissions (and indirectly, rewarding off-shoring of emissions and associated jobs).

Both traditional sector-based and the newer systems-based and consumption-related views are useful. But the systems-based view is more conducive to materials management policies and programs actions that offer a potent way for governments and communities to reduce GHG emissions. Materials management policies and programs are valuable approaches because they:
  • can result in communities, counties, and state agencies achieving faster and cheaper progress in reducing GHG than would be made otherwise;
  • are often more directly under the control of communities and jurisdictions than are energy supplies and regional transportation;
  • are subject to government purchasing power; and
  • increase local businesses and jobs – by increasing product stewardship¸ reuse, recycling and composting.
We endorse these recommendations:

1. The US Inventory should integrate “systems-based” greenhouse accounting -- and present it alongside the traditional sector-based view.

2. Consumption-related emissions should be formally acknowledged in the US Greenhouse Gas Inventory. The US Greenhouse Gas Inventory should be much more explicit in stating that the inventory is limited to emissions that physically originate within the national borders of the US. It should explain that the US also contributes to emissions that are counted in the inventories of other nations, as a consequence of imports.

3. Given the need to reduce the short-term impacts of greenhouse gases, the US Inventory should portray results using both 100-year, and 20-year Global Warming Potentials. While the IPCC standards require the use of 100-year Global Warming Potentials (GWPs), the Inventory correctly points out that other GWPs are also available, and including that analysis would be helpful to planners, policymakers, and the public.

[your name and/or organization here]

Sign on by April 8th at

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