Federal agencies will have to find ways of tracking and reporting their downstream carbon emissions, down to the level of their employees’ commuting and business travel, under a new set of White House instructions.
The rules from the Council on Environmental Quality, issued Aug. 31, will be especially tricky for large agencies, according to reporting specialists. Broadly, the instructions require agencies to set annual targets for lowering the greenhouse gas emissions that come from sources they don’t directly control, known as Scope 3 emissions.
Included in that category are transmission and distribution losses from purchased electricity, solid waste disposal, wastewater treatment, and many other activities.
Leah Dundon, an environmental attorney at Beveridge & Diamond PC, said indirect emissions will be difficult to measure accurately. That same concern has been raised by critics of the Securities and Exchange Commission’s recent proposed climate rule.
“It’s potentially a complex and huge undertaking, and will be more so for larger organizations, including federal agencies,” Dundon said.
Pentagon at Work
Andrew Mayock, the White House’s federal chief sustainability officer, said the emissions cuts are important because the federal government is “the world’s largest buyer of goods and services and the nation’s largest employer.”
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