Put Products and Packaging into US Greenhouse Gas Inventory

Submit Comments on the Draft US Greenhouse Gas Inventory by April 8th

EPA’S draft update of the US Greenhouse Gas Inventory (1990 – 2008) is open for comment. This is a great opportunity to get the systems -based, greenhouse gas accounting view added to the US Inventory.

While the US Inventory is required to follow international protocols (for the sake of consistency with other nations), EPA does have the latitude to include additional analysis, and to more clearly explain what the inventory is – and isn’t – portraying.

Both an EPA report and a Product Policy Institute (PPI) white paper issued in September 2009 showed that products and packaging (or goods and materials) are responsible for the largest share, by far, of U.S. greenhouse gas emissions – 44% when you include global emissions of products produced abroad and consumed in the US. Links to both PPI and EPA reports and a New York Times article are here.

Comments are due by April 8.

To view the draft and submit a comment online, go to this link.  Please ask EPA (in your own words) to consider the following:

1. The US Inventory should integrate the systems-based view and present it alongside the traditional sector-based view. EPA recently published a “systems-based view” see chart, p. 11, of GHG emissions. Coupled with the traditional sector-based view, the systems-based view offers a much more comprehensive perspective on how the US contributes to GHG emissions. The general public and local policy makers find the systems-based view to be very informative and instructional in developing personal and policy actions to address climate change.

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. The emissions associated with US exports are less than those associated with US imports. 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).

3. Given the need to reduce the short-term impacts of greenhouse gases, it would be very helpful if the US Inventory portrayed results using both 100-year, and 20-year GWPs. 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.