Measuring Emissions of Greenhouse Gasses: EPA Takes a Critical First Step

green 5 Measuring Emissions of Greenhouse Gasses: EPA Takes a Critical First Step

Watching the Obama Administration’s “green team” in action is inspiring. In a very short period of time, these folks have revitalized our environmental agenda. They are doing it with words and with deeds. While there is plenty of rhetoric and lots of symbolic action, there is also significant and important activity underway at the ground level.  Taken together, we are seeing a rapid repudiation of the Bush environmental legacy, along with the reversal of many of the Bush era’s environmental policies. 

On March 10, 2009 EPA took an important positive step under the Clean Air Act to begin the regulation of greenhouse gasses. At long last the U.S. government proposed a national system for reporting emissions of carbon dioxide and other greenhouse gasses.  According to EPA estimates, about 13,000 large facilities produce over 80% of the nation’s greenhouse gasses and those facilities are covered by the proposed regulation. Most of the information we have about the concentration of greenhouse gasses are estimates based on computer models.  This new rule starts the process of collecting detailed information on emissions, measured at the actual source of those emissions.  In order to implement policies to control and reduce greenhouse gas emissions, we need detailed information on who emits these gases and how much they generate.  We need to learn to collect, report, analyze and verify real data on actual emissions.

Lisa Jackson, EPA’s new Administrator, acknowledged the importance of this proposed  rule and observed that: “Our efforts to confront climate change must be guided by the best possible information. Through this new reporting, we will have comprehensive and accurate data about the production of greenhouse gases” 

The importance of this step cannot be minimized, and the absence of such a system made any discussion of reducing global warming little more than a symbolic exercise. The fact that EPA is getting serious about measuring the actual sources of greenhouse gas emissions tells you that they are finally serious about controlling them. A fundamental of management is that you can’t manage something unless you measure it. Measurement tells you if the actions taken by management are making things better or worse.  You can’t set a precise price on carbon unless you have real information on how much a source emits.

I know that some people find details like this boring and unexciting, but change in public policy always begins with ordinary, prosaic steps like this one. It’s important to understand that this is just a critical first step of a very long process. If EPA’s regulation survives the public comment period and is not delayed by the courts, the first reported data will not arrive until 2011. This means that regulations or carbon fees designed to reduce these emissions cannot be put into effect until these emission reports are submitted and verified.

While it will take a while to achieve reductions in greenhouse gasses, the first U.S. program to regulate carbon dioxide as a pollutant under the Clean Air Act is now underway. While we  need a law that will focus specifically on global warming, and we also need an international agreement, this is a good place to start.  EPA often begins new areas of regulation by reinterpreting existing laws. Before there was a Federal Water Pollution Control Act in 1972, EPA began regulating water pollution through the creative use of the 1899 Rivers and Harbors Act.  Even though that law was designed to keep the ports clear for shipping, its language could also be used to regulate discharges of pollutants in waterways near major cities. (We’ll leave out the fact that the Republican Nixon Administration focused its early enforcement efforts on cities with Democratic Mayors!)

Solving the climate crisis will require a series of concerted actions on a variety of fronts: 

- We need to develop cost effective renewable energy technologies.

- We need to learn how to sequester and store the carbon dioxide already in the atmosphere and the additional carbon to come. 

- Americans waste enormous amounts of energy– so one of the easiest things we can do is become more efficient in our use of energy.

- The global warming now under way requires that here in New York City we adapt our infrastructure to minimize damage from flooding. 

- National and international law must be established to reduce emissions of greenhouse gasses.

- We need to learn how to set a price for carbon that reduces the use of fossil fuels and encourages renewable energy but does not stunt economic growth.

The idea that we should choose among these actions is absurd. We need to do all of it as soon as we can. However, in order to reduce global warming, we must develop an effective and accurate system for measuring this type of pollution. On March 10, 2009, the EPA took an important and long overdue first step in this process.  Elections really do have consequences. Fortunately.