Should Ecology consider giving organizations credit for reducing their greenhouse gas emissions before the program begins?


Ecology has begun writing a rule that will limit greenhouse gas (carbon) pollution. In recent webinars, many people have asked if the rule will allow organizations to receive credit for reducing their greenhouse gases before the program begins.

Ecology is still in the early stages of the rule. All ideas and concepts are one the table for discussion. Please let us know what you think about giving credit for early actions.

Please share your thoughts. Click “leave a reply” below or the comment icon to the right of the question.

We appreciate your comments and questions. These communications are part of the public record but are not considered formal comments. The formal comment period will begin after we file the CR-102 form. We expect this to happen in December 2015.

10 thoughts on “Should Ecology consider giving organizations credit for reducing their greenhouse gas emissions before the program begins?

  1. Setting caps based on an industry wide benchmark of emissions per unit of output is one way of rewarding early action. While this this requires collecting data on product/output as well as emissions, it might be your best bet considering you are going to benchmark for new entrants, so will need the systems to do this no matter what.

    Including earlier years when defining the cap is also an option.

    Competitive distortion issues are especially challenging under your current design because the cap for a firm depends not just on how efficient their processes are but what fuel choices they have made. Firms that have a long term contract for supply using a fuel that has an upstream cap (petroleum products and natural gas) or electricity will be at an advantage compared to firms who have have their emissions directly capped.

  2. Only accredited emission reductions should be accepted. Prior reductions should be used as GHG reduction has been a global issue for many years. It would be counterproductive to penalize a facility that made changes to reduce GHG in 2011-2015.

  3. It is really important to not penalize early adopters that reduced their carbon emissions before the program begins, there are many good examples. Crediting those that began early is one good mechanism. Back dating the start of the program may be another.

  4. Rewarding companies that voluntarily reduced GHG emissions before 2016 sends the signal to industry that the State condones their early action, which could well incentivize industry that will not be covered by the new rule to also reduce their GHG emissions voluntarily.

    Otherwise, the incentive for any entity that is not yet subject to the rule, but anticipates being subject to the rule at some later date, is to boost their emissions now. Instead, we want to incentivize voluntary reductions now. This is why rewarding early adopters is important.

    Of course, those early emissions reductions need to be properly verified if they are to count. As M. Gillenwater pointed out above, California does this with a list of approved voluntary quantification programs.

  5. Please check out “The Climate Registry” at
    The Climate Registry (TCR) is a non-profit organization governed by U.S. states and Canadian provinces and territories. TCR designs and operates voluntary and compliance GHG reporting programs globally, and assists organizations in measuring, verifying and reporting the carbon in their operations in order to manage and reduce it. TCR also consults with governments nationally and internationally on all aspects of GHG measurement, reporting, and verification.

    I believe that if a company was serious enough to report their emissions and stand up to the scrutiny involved in verification as required by TCR, then their reductions in CO2e should be accepted.

  6. No. Many organizations and citizens have been trying to reduce their GHG emissions for years and the net result has been unsuccessful. GHG emissions keep rising. There is no fair way to accurately account for historical efforts and give credit for reductions that were made in the past. Most past efforts were made in order to reduce fossil fuel-based energy costs; reducing GHG was an afterthought. The metrics of GHG emissions have not been practiced consistently. Ecology’s new rules should define the baseline and standardize the metrics going forward. The environmental cost of GHG emissions is extremely high; much higher than anyone thought just 10 years ago. I expect to see Ecology develop strong incentives & disincentives that will change technology as well as organizational and individual behaviors to eliminate GHG emissions going forward.

  7. Granting credit for pre-period reductions is an ‘offramp’ in a carbon-capping initiative, and sends a weaker market signal to both obligated parties, who have less impetus to undertake reduction activities/make investments, but also to the cleantech/cleanenergy/cleanfuels sectors to bring their solutions to market.

  8. Happy to provide some “free” counsel on this issue, given that my organization, the Greenhouse Gas Management Institute, is based in Seattle. We professionals teach people globally how to become an experts on these issues.

    Here is a useful resources:

    There is a lot of confusion and misinformation on the topic of offsets. Our colleagues here in Seattle at the Stockholm Environment Institute also have a great deal of expertise on this topic.

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