EPA Guideline for Managing Greenhouse Gas Emissions
The EPA released a draft Guideline for managing Greenhouse Gas Emissions for comment. The following is the submission prepared by Dr Elizabeth Gibson, CMPA General Manager.
Purpose (taken from https://engage.vic.gov.au/new-draftguideline-managing-greenhouse-gas-emissions)
Greenhouse Gas (GHG) emissions create a risk of harm to human health and the environment as they contribute to an increase in climate change risks. This guideline forms part of the ‘state of knowledge’ about the risks of harm arising from GHG emissions, and ways of eliminating or reducing those risks, which people subject to the general environmental duty (GED) should reasonably be aware of.
The guideline outlines a risk management approach that can be applied to GHG emissions. It is designed to support Victorian’s conducting a business with direct or indirect GHG emissions.
The guideline will assist you to assess your GHG emissions and take reasonably practicable steps to eliminate or reduce your emissions as part of your contribution to reducing climate change risks, as it is the many contributions from human activities that leads to the increased GHG concentrations in the atmosphere.
The guideline will help you better understand how to identify and assess (for example, estimate, calculate) and manage (through implementing controls to minimise the risk so far as reasonably practicable) your direct and indirect GHG emissions.
Discussion
General:
The Guideline is impractical for small to medium business being 37 pages long with numerous references to other publications (5 pages of references at the end of the Guideline and references interspersed throughout the body of the document).
A quick search on the internet yielded simpler versions for measuring and reporting on GHG emissions:
• United Kingdom Department for Environment Food & Rural Affairs Small Business User Guide: Guidance on how to measure and report your greenhouse gas emissions (7 pages)
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/69494/ pb13310-ghg-small-business-guide.pdf
• United States Environment Protection Agency
Guide to Greenhouse Gas Management for Small Business & Low Emitters (19 pages)
Simplified GHG emissions calculator
Simplified Inventory Management Plan Form
https://www.epa.gov/climateleadership/ghg-inventoryguidance-low-emitters
It is unclear from reading the Guideline whether:
• It is mandatory;
• The GHG emissions data is to be submitted to the EPA.
Specific:
Submission
• CMPA supports the reduction or elimination of direct or indirect GHG emissions where reasonably practicable.
• Whilst it is assumed that the intent of the Guideline is not for small/medium businesses to engage expensive consultants to fulfill their obligations for the General Environmental Duty and GHG emissions, the Guideline recommends third-party independent verification.
• Clarity is required on whether the requirements in the Guideline are mandatory and where (or whether) the data collected on GHG emissions is to be submitted.
• The Guideline should be simplified, amended and/or separated to include a Template and/or Checklist for small businesses that may be more readily audited or revisited.
• The CMPA would be interested to work with the EPA to develop such a Guideline tailored to small/medium quarries including construction and demolition waste recyclers.
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