PlanetKeep.Org Response to RFI NNH23ZDA009L: Request for Information: DRAFT Federal Strategy to Advance an Integrated U.S. Greenhouse Gas Monitoring and Information System (GHGMIS)
INTRODUCTION
PlanetKeep.Org is a Non-Governmental Organization (NGO) that maintains a presence on social media intended to identify and share interesting and important information on climate change and sustainability, in a non-partisan manner.
The PK Team is highly encouraged by the idea of the GHG MIS in that it directly addresses the very real Big Data challenge of tracking performance towards our Carbon Neutrality goals. This tracking and course correction process will determine whether and how we meet the very real climate challenge. You cannot manage what you don’t measure, and without a management approach any attempt at efficiency or effectiveness is futile. Sharing information and details on important climate tech innovation and furthering the collaborative achievement of decarbonization is at the center of our organization’s objective. After review of the RFI we firmly believe that we are aligned with the GHG MIS goals. We are running out of time to decarbonize before even more dire climate impacts begin to occur. The GHG MIS, and its enabled programs, is offering critically important solutions.
The PlanetKeep Team’s response to the RFI is organized as follows:
1-GHG MIS DRAFT FRAMEWORK OVERALL SYSTEM ARCHITECTURE
2-RFI Category-ERRORS, OMISSIONS AND GAPS
3-RFI Category-NEW APPROACHES FOR COLLABORATION, FRAMEWORK, STRATEGY
4-RFI Category-COORDINATION MECHANISMS TO ADVANCE PROGRAM EFFECTIVENESS
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1-GHG MIS OVERALL SYSTEM ARCHITECTURE IMPLIED BY THE FRAMEWORK
a-The -Strategy Executive Summary implies that the Framework is aiming for a single national system “to inform mitigation efforts by a range of stakeholders”, i.e. a single system that provides everyone with all the emissions performance data products they need, all the time. This is to be done by “providing enhanced data products”, presumably deployed and managed by various federal agencies.
b-This approach needs to be assessed carefully and compared to more distributed system architectures, whereby more emphasis is placed upon helping stakeholders create and provide their own products consistent with a framework of federal standards, rules, procedures for aggregation, tools, and support.
c-Why a distributed approach? Sustainability-- for instance decarbonization-- is implemented largely at the community, county and state levels, in a myriad of ways (see FIGURE 1 for some dimensions of decarbonization, for instance). That requires some well-thought-out distribution of responsibility for data products, rather than parsing out traditional agency responsibilities.
d-In the distributed approach, it falls upon the framework to aggregate GHG MIS implementation into classes that can be supported, monitored and tasked to provide data products that are: 1) needed for their own management, and 2) can be aggregated at the next higher level.
e-A distributed approach will require the strategy framework development to collect input on experience regarding GHG monitoring and Information management from various levels or classes of implementers from various sectors of the economy, using various technologies, as reflected in their climate action plans and reporting.
2-RFI CATEGORY: ERRORS, OMISSIONS AND GAPS
a. No comments on errors and omissions as this is a very high level document. Regarding data gaps:
b. With the deployment of a large GHG data platform comes the need to define data quality objectives. This objective could be accomplished through the development of an Emissions Inventory and Monitoring Plan and Approach.
c. PK recommends that there be an enhanced Verification Program (similar to, or in conjunction with EUETS or CARB programs) to ensure emissions estimates are within 95% confidence.
d. A distributed approach might utilize an activity-based approach (bottom up) - perhaps a focus on the development of a detailed community data map and dashboard could be discussed in some detail in the GHGMIS.
e. Experienced GHG professionals understand that a lot more work is needed on the activity based approach as there isn’t accurate data on the real community-based carbon footprint (urban-based GHG emissions) as most communities only update inventories every 2-3 years and often use imprecise methods.
f. Please provide clarity regarding the cross-integration between bottom-up and top-down GHG inventory approaches. For instance, how does the IWG foresee this being executed operationally when good activity-based data isn’t really available due to “trade secret” and “privacy” restrictions imposed by utilities and private companies e.g. Large Gasoline retailers).
g. PK also recommends Transportation be addressed as a separate, distinct sector of emissions sources, as it is the largest global sector in terms of mass GHG emissions.
3-RFI CATEGORY: NEW APPROACHES FOR COLLABORATION, FRAMEWORK, STRATEGY OR DEMO PROJECTS
a. An important aspect of efficient collaboration will be to identify sectors at City/County levels to data map, database and dashboards (internal and external facing) – good for demonstration projects
b. Re aggregation of data could be achieved by, providing funding to regional collaboratives (e.g. Western Climate Initiative)
c. Funding for enhanced monitoring at Net Zero buildings and developments is needed
d. Enhanced monitoring is needed for reductions and sequestration projects/programs
e. Provide funding to NGOs (e.g. Sustainable Lafayette) to track smaller, local sources and to test and demonstrate aggregating data with other entities
4, -RFI CATEGORY: COORDINATION MECHANISMS TO ADVANCE PROGRAM EFFECTIVENESS
a. Must emphasize bringing large emitters to the table (e.g. O&G, Utilities) through incentives or compliance penalties
b. Aggregate fuels/utility data through point-of-use revenue meters where possible
c. Designate funding and regulatory authority to large regional entities to aggregate and track emissions (e.g. CARB in California)
d. Provide guidance on standardizing GHG calculation methods at needed levels of aggregation (e.g . GHH Protocol, other methods, USEPA CAA CEMS guidance
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