Title: [GreenYes] ICLEI draft protocol
ICLEI has extended the comment period on their Local Government Protocol
until February 29th. If you want to register to read it and provide
feedback, go to http://ghgprotocol.iclei.org.
From my read (and my knowledge of such protocols is poor), there are
some significant flaws in how the protocol handles waste. Basically, it
only looks at the waste actually disposed by or in the municipality. So
there is no accounting for embodied energy, etc. I submitted the
following two comments; Peter Anderson has some very good comments about
landfill gas, and a couple of other people have put in useful comments
as well. I'd encourage you to also submit comments, to try to nudge
ICLEI into taking waste reduction/recycling more seriously.
FYI, here are my comments. Feedback welcome, of course.
Unless I have misunderstood the protocol, there is a serious flaw
here in that it does not properly address the GHG effects of waste
reduction and diversion. Obviously, this is a thorny question of
system boundaries; it is not clear where the GHG savings associated
with these activities should lie.
As I understand the protocol as written, the inventory is based only
upon actual waste disposed (i.e., sent to incinerator or landfill).
This fails to differentiate between waste reduction, reuse, and
recycling, which have very different effects on GHGs. More
importantly, it implicitly attributes those GHG savings to other
sites in the economy, outside the purview of local governments
(manufacturing, transportation, or raw material extraction, for
example). Yet the decision on how to handle waste is being made by
the local governments. This sets up a disconnect between the ability
of local government to significantly reduce their carbon footprint
and the "credit" they would receive for it under this protocol.
The IPCC recognizes this difficulty by indicating that the potential
reductions in GHGs from proper waste management actually exceed the
total GHGs emitted from the waste sector. Obviously, this is because
of the complex way that waste penetrates system boundaries.
Unfortunately, this protocol seems to ignore that issue.
One way to remedy this without drastically expanding the system
boundary would be to calculate the embodied energy of the disposed
waste, and assign a GHG value to that energy based on current use of the
I would echo the concern about simply dismissing biogenic carbon. As
Glen Svendsen says, the theory behind this approach is weak. Soil
scientists are still trying to grapple with the question of how much
carbon is stored in soil and how to measure its flux; to assume that
those measurements, somewhere in the world, will capture the
additional release or sequestration of carbon by a municipal
government is simply unrealistic.
In addtion, there are other issues about how biogenic carbon affects
other processes. For example, compost that is returned to the soil
not only contains a significant amount of carbon itself, but enriches
the soil with micronutrients, encouraging plant growth and thus
carbon intake; it can also displace the use of chemical fertilizers.
Composting is therefore significantly more beneficial than
incineration or landfilling of biogenic carbon-containing wastes. Yet
the protocol does not reflect this.
There is also the thorny issue of short-term sequestration. While the
IPCC considers sequestration of under 100 years to be
inconsequential, there is obviously an important difference between
binding carbon for 50 years in a stable matrix (such as wood) and
releasing it immediately (such as by burning it). This is all the
more important when one considers the possibility of a tipping point
in the next 5-10 years.