The Greenhouse Gas Protocol ("GHG Protocol" or "Protocol")—a leading standard setter for measuring and managing corporate greenhouse gas emissions, borne of a partnership between World Resources Institute (WRI) and the World Business Council for Sustainable Development (WBCSD)—has opened stakeholder surveys concerning the revision of its Corporate Accounting and Reporting Standard, Guidance on Scope 2 Emissions, and the Scope 3 Standard and Scope 3 Calculation Guidance.
The GHG Protocol's standards and guidance are a foundational element of the Science Based Targets initiative (SBTi), which helps shape and verify corporate emissions reductions targets and ensure they are aligned with the goals of the 2015 Paris Agreement.协议是大企业首选碳核算机制:2016年92%以上Fortune500公司向CDP报告排放数据时,根据Hgorm协议会计标准这样做。万博体育app手机登录自2004年以来公司会计报告标准从未修订过,范围2排放指南-即自2010年代初首次发布以来与公司电热三维排放相关联的排放量从未修订过。
i2022年3月宣布利害关系方调查过程时,《温室气体议定书》宣布,“关键焦点将是通过重大披露举措确保与正在开发的核算规则相统一和一致..信息披露创举多多样,跨行业和司法权限,但关键共性在于依赖温室气体协议当前框架 。
,例如,美国证券交易委员会s/www.cov.com/en/news-and-inights/inights/2022/03/sec-proposes-landmark-climate-证交会在其提案中明确纳入并采纳了由《温室气体协议》开发的许多概念。
II万博体育app手机登录可再生能源证书作用2范围发布指南
A万博体育app手机登录RECs当前在2范围报告
Hrefss/default/files/Scope%2020Guidance_Final_Sept26.pdf>>当前2范围指导 (发布于2015年)为实体报告2范围排放量框架-即购买电耗、蒸气、热和冷却间接排放当前,实体可以通过定位法(基于实体地理区域平均产生能源排放量)或市场法(基于实体购买RECs的具体生成器排放物)报告CLE2排放量。
RECs是再生电源发布并出售给其他实体的工具,这些实体可能与直接购买电力合同捆绑或不可包绑万博体育app手机登录当前指南解释RECs销售传递可再生能源需求信号,这些信号驱动生产变化万博体育app手机登录RECs设计创建需求端市场信号,当前指南不要求实体证明RECs额外性也就是说,实体无需证明将排减纳入REC兆瓦本不会实现万博体育app手机登录数个其他报告机制,如英国绿楼理事会净零碳建框架,包含 这一额外性需求协议正考虑改变RECs
A部分修改中,协议似乎在重新评估是否和如何计算RECs协议2022年3月公告宣布由Anders Bjorn研究范围2,夏季Bjorn 二大建议 For each of these fifteen categories, the Guidance prescribes a time boundary to account for all emissions related to the entity's activities in the reporting year, even if those emissions occurred in a prior year or are expected to occur in a future year.万博体育app手机登录计算指南还就每一类别规定了一套专用计算排放法。万博体育app手机登录举例说,购买商品和服务产生的排放可用供应商专用法报告(有特定供应商提供的数据)、混合法报告(有某些供应商提供的数据和二级信息补缺)、平均数据法报告(有货物质量和平均排放因子数据)或开支法报告(有货物经济值和平均排放因子数据) C拟议的改变将显著效果报告2排放
Upstream Downstream emissions from purchased goods and services downstream transportation and distribution capital goods processing of sold products fuel- and energy-related activities (not included in scope 1 or scope 2) use of sold products upstream transportation and distribution end-of-life treatment of sold products waste generated in operations downstream leased assets business travel franchises employee commuting investments upstream leased assets IVsites/default/files/mocket-bases%20Survey%20Memo.pdf如上所述,基于市场的核算方法涉及使用合同工具或抵减信用量测量排放量性能,而《温室气体议定书》允许这些方法处理范围2排放问题。万博体育app手机登录然而,当前指南不包括基于市场报告直接(范围1)或供应链排放(范围3)的计算方法这份调查请求利害相关方反馈各种市场化计算方法-包括抵减信用额、嵌套信用额、供销棚/价值链干预、批量平衡认证和书籍填报证书-可能应用到范围1和3排放报告上。
V万博体育app手机登录公司应该从此难得机会生成碳规则
In a series of prior blog posts, we previously highlighted the historic implications of the Inflation Reduction Act (IRA) for the U.S.'s international climate commitments, as well as for private companies navigating the energy transition. Shortly after our series published, the Senate passed the IRA on Sunday August 7th with only minor modifications to the bill's $369 billion in climate and clean energy spending. Today, the House passed the IRA without any further changes, and soon hereafter President Biden is expected to sign it into law.
However, this is only the beginning of the road!IRA四角将产生广度效果。 未来数月和数年中,我们期望看到对机构规则的强力操纵将决定IRA实施,并判定它作为能源策略的最终成功
As an initial matter, it seems Congress has not finished its work revamping the nation's climate and energy laws. As part of his agreement to support the IRA, Senator Joe Manchin (D-WV) announced that "President Biden, Leader Schumer and Speaker Pelosi have committed to advancing a suite of commonsense permitting reforms this fall that will ensure all energy infrastructure, from transmission to pipelines and export facilities, can be efficiently and responsibly built to deliver energy safely around the country and to our allies." While the exact contours of this legislation are not currently known, Senator Manchin's office recently released a legislative framework, which includes proposals to, among other things:
- tighten environmental reviews under the National Environmental Policy Act (NEPA);
- clarify the permitting and regulatory authorities of the Department of Energy and the Federal Energy Regulatory Commission;
- reform Clean Water Act provisions that allow state and local governments to impose additional requirements on federal permits!and
- create a list of strategically important energy projects, that the President can designate and periodically update, for streamlined permitting reviews.
According to Senator Manchin's office, permitting reform will receive a vote before the end of the fiscal year on September 30, 2022. Unlike the Inflation Reduction Act, which passed through arcane rules of reconciliation—and thus required only a simple majority—permitting reform will be subject to the Senate filibuster and require the support of at least 60 senators (and bipartisan agreement) to become law. At the moment, it is unclear whether broad bipartisan support exists for this measure!some Republicans have publicly signaled skepticism, and environmental activists have long opposed expedited fossil fuel permitting.However, in the past Republican Senators have expressed an interest in speeding the nation's permitting system. During this Congress, a bipartisan group of Senators introduced a law to accelerate infrastructure permitting, and all Republicans and Senator Manchin supported a resolution to disapprove of recent revisions to NEPA. Together, these actions suggest there may be some interest within the Republican caucus in implementing meaningful changes to current law, partisan divisions notwithstanding.
II.万博体育app手机登录减通货膨胀法关键赋值指南 外加,IRA本身有几部分未来数月将通过行政引导和规则制定过程予以澄清和实施守法标准支付工资、学徒和家用内容要求并计算温室气体排放法新税抵免 。
ahrfss/www.insideEnergyandense.com/2022/07/enger-support-for-电机-车-车-车-门-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电链/>这些规定并不适用于商业电车信用分量 。 具体地说,法律要求电电池组件的一定比例为“制造或组装北美 ”, 并适用百分比逐年变化 。 法律还要求电池中关键矿产品中一定比例为“提取或处理 ”, 在美国或与美国相邻的任何国家中实现“提取或处理 ” 。IRA § 13401(e).鉴于电车供应链的现状,预计许多汽车制造商难以满足这些外包需求万博体育app手机登录
However, key features of these clean vehicle credits have yet to take shape. By the end of this year, the IRA requires the Treasury Department to issue regulatory guidance to help shape and administer the battery and mineral sourcing requirements. Id. Among the questions open for interpretation are acceptable methods for calculating the "percentage of the value" for critical mineral and battery components, as well as better defining the terms "manufacture or assembly" and "extraction or processing." How Treasury addresses these points will have significant ramifications for the short- and medium- term value of the clean vehicle credits.
A much broader set of IRA tax credits seek to promote investment in, and use of, clean electricity, but their value depends on the interpretation of key labor and domestic content requirements. As currently structured, the IRA extends and modifies the Investment Tax Credit and Production Tax Credits that apply to certain renewable sources of power through the end of 2024. Id. §§ 13101, 13102. Beginning in 2025, similar projects will also be eligible for a new technology-neutral Clean Electricity Production Credit and a Clean Electricity Investment Credit, which apply to any domestically produced electricity source with a greenhouse gas emissions rate of zero. Id. §§ 13701, 13702. These credits, and others throughout the IRA, are keyed to the satisfaction of prevailing wage and apprenticeship requirements.
Specifically, if these wage and apprenticeship requirements are not satisfied the credits are worth five times less than they otherwise would be. Additionally, the IRA creates a 10% "domestic content bonus" when facilities certify that certain percentages of steel, iron, and other manufactured products used in the facility are made in America, and further increases the value of the credit for projects located in "energy communities," i.e.棕田网站或经济困境前化石燃料生产网站解释应用将极大影响政府可用支持值。 未来清洁能源项目必须注意确保适当文档并遵守这些条款Finally, many IRA tax credits are pegged to a demonstration of the life-cycle emissions of the underlying facility or fuel. For instance, the value of the clean hydrogen credit varies based on the project's "lifecycle greenhouse gas emissions rate." On the high end, a 100% credit value is awarded to projects with a lifecycle emissions rate of less than .45 kilograms (kgs) of carbon dioxide equivalent (CO2e), but on the low end, projects only receive 20% of the credit value if their emissions rate is between 4 and 2.5 kgs of CO2e. Id. § 13204. Additionally, the availability of the new credit for sustainable aviation fuels depends on a certification that the applicable fuels achieve at least a 50% life cycle greenhouse gas reduction percentage compared to petroleum-based jet fuel!燃料项目再为生命周期温室气体排放量增量百分比增量增益Id.
The full implications of the IRA are yet to be understood. The law is likely to have significant implications for our energy future, leading to sharp growth in the nation's clean energy production and a decline in national greenhouse gas emissions. Though we have laid out some initial consequences, there are undoubtedly many more interpretive questions that will arise in the coming weeks, months, and years. Additionally, by subsidizing and lowering the costs of clean electricity and other low-emissions technology, the IRA could improve the benefit-cost analysis for a variety of environmental regulations, leading to more stringent and durable rules. Further, by bolstering the domestic energy industry, the IRA could alter the political economy of climate policy, creating a broader base of support for future government investments in clean energy production or greenhouse gas curtailment. Regardless of how this future unfolds, it will surely be a dynamic time for energy and environmental law and policy.
This package presents the opportunity for Congress to finish legislating President Biden's Build Back Better agenda, completing the story detailed in our series The ABCs of the AJP. As we left the saga last summer, we noted that the effort to enact that agenda was Not Broken, Simply Unfinished. Today we are updating that series to detail the following energy related elements of the IRA:
- Accelerating efforts to decarbonize the economy and address climate change
- Ten year stability for expanded clean energy tax credits
- New funding for a National Green Bank through a Greenhouse Gas Reduction Fund
- The Creation of a Methane Emissions Reduction Program
- Strong support for the electric vehicle sector and domestic supply chain
- Empowerment of environmental justice
As President Biden noted yesterday, "Sometimes seem like nothing gets done in Washington ...但政府工作可能缓慢和沮丧,有时甚至令人厌烦。 之后拒绝放弃支付的人辛勤工作时日月数计算。历史成真。生活变换 。 至此,这些情感可能还为时过早!Arizona-Has/news/2022/07/28/dmocrats-climate-xacco-Service-Bill-reces-00048459能源和气候政策,随着法案跨过立法过程最后阶段,我们将继续更新和补充覆盖量。
In the July 14 memorandum, Commerce seeks information about the: (1) amount of investment necessary to construct and start-up certain facilities, (2) non-financial barriers (e.g., access to inputs, qualified technical employees, technologies, research and development, etc.) that companies typically face to establish and begin certain operations, and (3) research and development ("R&D") expenses associated with conducting certain operations. These types of facilities/operations involved in:
- refining silicon into solar-grade polysilicon,
- producing ingots from solar-grade polysilicon,
- producing wafers from solar-grade ingots,
- producing solar cells from wafers,
- producing solar modules from solar cells, and
- the same operations and products as foreign producers and exporters responding to Commerce's solar circumvention inquiries.
The agency is particularly concerned with facilities located, and operations performed, in mainland China, Cambodia, Malaysia, Thailand, or Vietnam, but would accept information pertaining to other countries.
Commerce is required to consider the level of investment and R&D expenses where circumvention is alleged due to assembly in a third country. Level of investment and R&D expenses are factors that statutorily must be considered when Commerce assesses whether the processing occurring in Cambodia, Malaysia, Thailand, and Vietnam is "minor or insignificant."[2] It is therefore important that interested parties provide Commerce with the requested information by the fast-approaching deadline of July 21st.
Commerce has requested this information only from "interested parties" in the solar circumvention inquiries which are defined under Commerce's rules to include foreign producers and U.S.Covington完全可以帮助客户响应商务请求提供事实信息或对商业规避查询有更广泛问题瑞格公元前19 0712022.
s1677j(b)(2).While the proposed rules would represent a positive development for foreign manufacturers, U.S.进口商和美国消费者,包括美国太阳项目开发产业,如果以当前形式发布,修改规则是可能的。因此,商务悬疑查询方必须在2022年8月1日之前提交评论 。
The proposed rules directly respond to President Biden's June 6, 2022 emergency declaration, which found that an emergency exists "with respect to the threats to the availability of sufficient electricity generation capacity" and authorized Commerce to issue a moratorium on tariffs on solar cells and modules from Cambodia, Malaysia, Thailand, and Vietnam for up to a 24-month period.[4]
The Proposed Rules
The proposed rules appear to respond to concerns raised by the solar project development industry about how the emergency declaration would be implemented in the context of existing agency regulations. Commerce has confirmed that it intends to provide for the temporary, duty-free importation of certain solar cells and modules from Cambodia, Malaysia, Thailand, and Vietnam even if Commerce determines that they are circumventing an existing AD/CVD order. In so doing, Commerce has clarified that these new rules—and not the agency's existing circumvention regulations—will apply to such solar cells and modules throughout the pendency of the emergency period.
The proposed rules would be codified as a new part 362 to title 19 of the Code of Federal Regulations, and they would provide that:
- The applicable entries would be those "Southeast Asian-Completed Cells and Modules" that are subject to the solar circumvention inquiries. "Southeast Asian-Completed Cells and Modules" means solar cells and modules completed in Cambodia, Malaysia, Thailand, or Vietnam, using parts and components that are made in China and "subsequently exported from Cambodia, Malaysia, Thailand or Vietnam to the United States."
- The date of termination of the temporary duty-free importation would be June 6, 2024, or the date when the emergency is terminated, whichever occurs first.
- Importation of Southeast Asian-Completed Cells and Modules would be "free of collection" of AD/CVD cash deposits until the termination date of the emergency.
- In the event of an affirmative preliminary or final circumvention determination prior to the date of termination, Commerce would not direct U.S.Customs and Border Protection to suspend liquidation or collect cash deposits. This means that Southeast Asian-Completed Cells and Modules imported at any time prior to the termination of the emergency would not be subject to AD/CVD duties as a result of an affirmative determination in the circumvention inquiries.
- In the event that it issues an affirmative preliminary circumvention determination, Commerce has signaled that it may require certifications for solar cells and modules from Cambodia, Malaysia, Thailand, and Vietnam in order to differentiate between (i) Southeast Asian modules with Chinese cells that are already subject to the existing orders and (ii) Southeast Asian modules using Chinese inputs that would become subject to the existing orders solely based upon an affirmative circumvention finding. This certification process would likely create an administrative burden for U.S.进口商
a美国成员太阳能电池制造行业Auxin Solar公司请求绕行查询,因此可能有兴趣对受影响的进口品保持高关税。商业有义务考虑所有提交的评论并可能根据这些评论修改拟议规则。 机构必须听取所有各方的意见,包括那些支持当前形式拟议规则者的意见,以便机构能够充分理解修改规则的后果。Covington深入处理国际贸易和能源问题,完全有能力帮助想提交评论或可能质疑新规则会如何影响业务的客户。