HomeMy WebLinkAboutMemo - Mail Packet - 3/31/2020 - Memorandum From Ippu Core Team Re: Industrial Processes And Product Use Emissions - Recommendations For Community Carbon Reporting1 | P a g e
Environmental Services
222 Laporte Ave
PO Box 580
Fort Collins, CO 80522
970-221-6600
fcgov.com
MEMORANDUM
Date: March 25, 2020
To: Mayor and City Council
Thru: Darin Atteberry, City Manager
CAP Executive Team1
From: IPPU Core Team2
Re: Industrial Processes and Product Use Emissions – Recommendations for Community
Carbon Reporting
The purpose of this memo is to provide recommendations for addressing industrial process and product use
(IPPU) emissions in community carbon reporting, including the annual community inventory. The
recommendations are based on peer city research, dedication to transparency, and the impact on accuracy of
incomplete available data.
Bottom Line
Staff recommends creating a second inventory that includes IPPU, reported side by side with an inventory that
follows current methodology, for 2019. This recommendation follows Global Protocol for Community-scale
Greenhouse Gas Emission Inventories (GPC) BASIC reporting guidelines while also including this additional
recommended emissions source (Option 1). Context for staff’s recommendation is the following:
• Peer city research. Nine peer cities that report IPPU emissions to the Carbon Disclosure Project (CDP)
were researched to understand common approaches to this question. Three of these cities chose to
report two inventories side by side: a “core inventory” with traditional resource areas that is measured
against the community’s goals, and an “expanded inventory” with traditional resource areas plus IPPU
and other emissions (see Attachment 2 for a full description).
• Inventory transparency. This option maintains the ability to compare 2019 inventory results to the 2005
baseline, while providing transparency regarding industrial process emissions.
• Inventory baseline and Alignment with Climate Goals. Currently IPPU data is available for 2011 to
2018, not back to the 2005 baseline. More discussion of backcasting to 2005 is below and in Attachment
3. The inventory with core resource areas (i.e. electricity, natural gas, ground transportation, waste, and
wastewater) is recommended to still be used to compare to baseline for the purposes of tracking the
community’s progress toward climate action goals both because the goals were set with these resource
areas and due to lack of IPPU data.
Alternative Options
In addition to the recommendation described above, staff considered the following options, ordered by level of
recommendation:
• Option 2: Maintaining current inventory methodology for 2019 and adding a suite of complimentary
measures that are reported side by side.
• Option 3: Making no change to current inventory methodology and reporting.
• Option 4: Creating a new inventory which includes known IPPU emissions using available data back to
2011 (not recommended).
1 Deputy City Manager Jeff Mihelich; Utilities Executive Director Kevin Gertig; Director of Planning, Development, and
Transportation Caryn Champine; Chief Sustainability Officer Jackie Kozak Thiel; & Environmental Services Director Lucinda
Smith
2
Environmental Services Director Lucinda Smith; Climate Program Manager Lindsay Ex; Senior Economic Manager SeonAh
Kendall; Energy Services Senior Manager John Phelan; Customer Accounts Manager Mark Cassalia; Air Quality Program
Manager Cassie Archuleta; Sr. Specialist Molly Saylor; Sr. Specialist John Graham; Sr. Specialist Adelle McDaniel; & Climate
Economy Advisor Sean Carpenter
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Attachment 1 summarizes the pros and cons of each option. Along with the recommended Option 1, staff
recognize the Our Climate Future (OCF) planning process will update climate, energy and waste polices and
consider the scope of community emissions, which includes a review of metrics and reporting.
Council Direction
With Council direction last July (2019), staff began including known sources of IPPU emissions within inventory
summary reports online (https://www.fcgov.com/climateaction/reports.php) and have committed to including this
information on the CAP Dashboard (https://ftcollinscap.clearpointstrategy.com). In a November memo (see
Attachment 4, which also includes background information on what IPPU emissions are), staff committed to the
following next steps, which are summarized below:
(1) Conduct peer city research regarding tracking and potential mitigation actions for IPPU emissions.
(2) Continue exploring options with known large IPPU emitters for tracking and potential mitigation options.
(3) Continue exploring with the State regarding potential tracking, reporting and mitigation of IPPU emissions.
(4) Explore IPPU emissions within the broader OCF planning process.
In their March 3, 2020 meeting Councilmembers also directed staff to consider an option for a single integrated
inventory that included IPPU emissions (Option 4), including a description of how the data could be estimated
back to 2005. The remainder of this memo represents the context for staff’s recommendation in the Bottom Line.
Context of Recommendation
Peer City Research
Staff worked with Carbon Disclosure Project (CDP), a global reporting platform for carbon inventories, to research
which cities and counties include IPPU emissions in their inventories (see Attachment 2 for detailed peer city
research information). Approximately 180 U.S. cities publicly report their community inventories using this
platform. Of those 180, about 20 note they include some emissions that fall within the IPPU sector. Staff is not
able to ascertain if any of the other 160 cities do have large emitters that they do not include in their inventories.
Staff researched the nine most comparable cities and counties that reported IPPU emissions. Reporting methods
of these communities can be summarized in three general types: (1) reporting an inventory according to BASIC+
requirements, (2) reporting two inventories, one not including IPPU (“core”) and one including IPPU (“expanded”),
and (3) reporting a single integrated inventory. Regardless of approach, each community (except for Boulder
County) had data back to their baseline year. Boulder County chose to present all available information in their
most recent inventory and noted included IPPU emissions without data back to the baseline year made
comparison to previous inventories and communication about reductions more challenging.
Of the communities staff talked to, all were working with businesses regarding environmental topics, though few
were working directly on IPPU emissions. Staff from Austin were just beginning to convene meetings with
semiconductor industry partners to discuss possible solutions. Staff is also aware that Cleveland is working with
their industry partners but were not able to connect directly to discuss their practices.
Work with Known Large Emitters to Understand Data Availability and Actions Taken
In 2009, the U.S. Environmental Protection Agency (EPA) published a rule for the mandatory reporting of
greenhouse gases (GHG) from sources that in general emit 25,000 metric tons or more of carbon dioxide
equivalent per year in the United States. The rule requires specific facilities that emit significant quantities of
fluorinated gasses to report their annual emissions. Because of the EPA threshold, the community is able to
identify one industry source in Fort Collins (Broadcom) as a large IPPU emitter. Other IPPU emission sources
may exist in Fort Collins but fall below the EPA reporting threshold.
From conversations with Broadcom, staff has learned the following:
• Broadcom is a part of the state’s Environmental Leadership Program. As a part of this commitment, they
have established several environmental objectives, one of which is to reduce greenhouse gas emissions.
• In accordance with these commitments, Broadcom has installed 10 abatement devices on their highest
SF6 usage tools (which destroy over 90% of SF6 emitted).
• Broadcom is actively evaluating new tools and additional abatement as new equipment is brought online
at the Fort Collins facility.
• Broadcom also noted the EPA report illustrates that emissions have reduced since 2016, even while
undergoing an increase in production.
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Broadcom has indicated they are not able to share production and emission data back to 2005, and the only data
available are the data posted on the EPA’s website (beginning in 2011, when the reporting requirement began).
Inventory Baseline
Councilmembers directed staff to include an option with a single integrated inventory with IPPU emissions and a
description for estimating data back to 2005 (Option 4). While Broadcom (formerly Avago) was operating in Fort
Collins prior to 2011, the EPA did not require emissions reporting prior to that date. As a result, IPPU (in this case
SF6) emissions information is not available from 2005 through 2010.
Options for estimating IPPU emissions from Broadcom that have been considered include:
• Calculating an average from 2011 to 2018 data and using this value back to 2005;
• Holding the 2011 value back to 2005;
• Using data from 2011 to 2018 to create a backwards linear estimate of IPPU emissions to 2005; or
• Seeking to identify a proxy indicator with which to correlate Broadcom’s IPPU emissions. Further research
would be necessary to establish how robust this estimate could be.
Using one of these methods to create a placeholder for this sector of emissions back to 2005 may only have
limited ability to help us understand the changes in emissions occurring in our city and take action to reduce those
emissions. Because the 2011 to 2018 emissions data do not follow a linear trend, it is challenging to estimate the
prior years. Staff recommends reporting two inventories and continuing to compare to baseline using the “core”
inventory due to this challenge of not having an accurate understanding of emissions between 2005 and 2010.
See Attachment 3 for a visual representation of these estimates.
Update on Statewide tracking and progress
The State is in the process of evaluating and updating their greenhouse gas inventory. Currently, proposed
rulemaking requires reporting of industrial process emissions at the same threshold as the EPA, meaning no new
data would emerge from this action on smaller IPPU sources. Through Colorado Communities for Climate Action
(CC4CA), staff is recommending the State make its process for deciding these thresholds more transparent and
lower in cases where many small point sources together are equal to a large emissions source. Further, it is
currently unclear whether the State will include data from 2005 as part of its rulemaking. Data and opportunities
may arise out of the State’s work; for example, it may be possible to align with statewide standards to ensure
greater consistency for IPPU emissions tracking.
Update on Our Climate Future (OCF) Process
Throughout the OCF process, the City, community partner organizations, and community members together are
refreshing Fort Collins’ understanding of climate action work, as well as reassessing ownership of this work.
Though the City currently relies heavily on the single indicator of the carbon emissions inventory, it will never paint
a full picture of equitable climate action. Recommendations from the community may include new emphasis on
decision-making based on additional metrics outside the inventory and adding new greenhouse gas sources.
Recommendation
Staff recommends creating a second inventory with industrial process emissions integrated, reported side by side
with an inventory that follows current methodology, for 2019 (Option 1).
Next Steps include:
• If Council supports staff’s recommendation, staff will begin creating the second, expanded inventory, to
be reported in parallel to the 2019 inventory that follows current methodology (expected to be completed
this summer).
• April 28 Work Session with City Council to review Our Climate Future progress overall.
• In 2020, climate and emissions metrics will be evaluated and modified, as needed, through OCF, and will
be communicated with Council via upcoming memos and Work Sessions related to the planning process.
Attachments:
(1) Summary of options
(2) Peer City Research
(3) Inventory Baseline
(4) November 2019 IPPU Memo
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Attachment 1: Summary of Options
Option Benefits Challenges
Option 1 (Recommended): Creating a
second inventory that includes IPPU for 2019,
reported side by side with an inventory that
follows current methodology
• Provides transparency
• Retains ability to compare to 2005 baseline for
purposes of tracking progress toward climate
action goals
• Follows peer cities work
• Does not address lack of data back to
2005 baseline
• Could create two separate messages
about emissions reductions, which peer
cities have shared has been confusing
for community members
Option 2: Maintaining current inventory
methodology for 2019 and adding a suite of
robust, complimentary measures that are
reported side by side
• Acknowledges that there are emissions outside
the scope of the inventory other than industrial
process emissions (e.g. ownership electricity
emissions, supply chain emissions)
• Maintains ability to compare to 2005 baseline
• Allows for a more comprehensive and
community-driven approach to updating
metrics through the Our Climate Future
process
• May appear the City is not tracking
significant source of known community-
based emissions
Option 3: Making no change to current
inventory methodology
• Maintains ability to compare to 2005 baseline
• Allows for clear communication about progress
or regression within the primary inventory
resource areas
• Matches the sectors goals were based upon
• Does not provide community full
transparency regarding known industrial
process emissions in Fort Collins
• Limits evolution of understanding of
emissions in Fort Collins
Option 4: Create one integrated inventory to
include large emitters within IPPU, using
available data back to 2011
• Improves transparency
• Leverages available data
• Without an accurate baseline to compare
each year’s emissions to, we would not
be able to report reductions with a
reasonable level of certainty.
• Inclusion of IPPU emissions may require
a rethinking of climate action goals, as
the goals were not set with IPPU
emissions included.
• Introduces confusing messaging about
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Attachment 2: Peer City Research
Staff worked with Carbon Disclosure Project (CDP), a global reporting platform for carbon inventories, to research
which cities and counties include IPPU emissions in their inventories. Approximately 180 U.S. cities publicly report
their community inventories using this platform. Of those 180, about 20 note they include some emissions that fall
within the IPPU sector. Staff is not able to ascertain if any of the other 160 cities do have large emitters that they
do not include in their inventories. Staff researched the nine most comparable cities and counties that reported
IPPU emissions to CDP, with a summary of the findings below:
• Side by side reporting (comparable to Option 1) (Dallas, TX; Louisville, KY; and Seattle, WA)
o These three cities report two versions of their inventories side by side. For example, Louisville
reports one inventory that does not include IPPU and agriculture, forestry, and land use (AFOLU)
(“core inventory”) and one that does (“expanded inventory”) in the same report.
o Louisville notes in their inventory report that AFOLU and IPPU typically serve regional and state
demands and are therefore more difficult to influence. They also noted they will continue to
monitor these sectors and look for opportunities to influence them, even though they are not
planning to set specific GHG reduction targets related to IPPU and AFOLU sectors.
o Both Seattle and Louisville would have seen greater reductions in emissions if they had included
industrial process emissions in their core inventory. By retaining two inventories, they can more
clearly communicate reductions that stem from City and resident changes separately from those
resulting from external changes.
• Reporting due to importance in a single integrated inventory (comparable to Option 4) (Austin, TX;
Cleveland, OH; Philadelphia, PA; and San Antonio, TX)
o Multiple cities reporting IPPU emissions included them because of applicability to their city. For
example, Cleveland’s IPPU sector makes up approximately 34% of their emissions inventory.
Their inventory report notes industrial process emissions have gradually risen in a trend
correlated to an increase in local GDP.
o Philadelphia reported a combined sector of fugitive and process emissions, which in total
represented 10% of their most recent inventory from 2012. The primary source of process
emissions was SF6 from a refinery operated by Philadelphia Energy Solutions, which has since
closed. This large change for their future inventories indicated to Fort Collins staff that significant
changes external to City and resident action have the potential to falsely communicate progress.
o Austin and San Antonio’s IPPU sectors make up 8% of each of their respective inventories. Both
cities report at a BASIC level and have chosen to include the IPPU sector within their reports, and
both have comparison data back to their baseline year. With this comparison data back to their
baseline years, they are able to more clearly communicate changes in their inventories due to
unique progress.
• Commitment to BASIC+ Reporting (Boulder County, CO and City and County of Honolulu, HI)
o These communities choose to report at a BASIC+ level, which means they are required to report
IPPU and AFOLU emissions.
o Boulder County staff noted they use BASIC+ because they want to be as transparent as possible
and include all available data. However, they noted that when industrial process emissions were
added to the newest Boulder County inventory, it became difficult to communicate changes in
reported values because the IPPU emissions were not included in previous inventories. Because
they did not have IPPU data back to their baseline year, they could not easily track progress.
Though they noted this as a challenge, Boulder County staff said they preferred presenting all
available information.
Of the cities staff talked to, all were working with businesses regarding environmental topics, though few were
working directly on IPPU emissions. Staff from Austin were just beginning to convene meetings with
semiconductor industry partners to discuss possible reduction strategies. Other cities discussed energy emissions
reductions with businesses. Staff is aware that Cleveland is working with their industry partners but were not able
to connect directly to discuss their practices.
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Attachment 3: Single Inventory Option with Estimated Baseline
Councilmembers directed staff to include an option with a single integrated inventory with IPPU emissions and a
description for estimating data back to 2005 (Option 4).
Although Broadcom (formerly Avago) was operating in Fort Collins prior to 2011, the EPA did not require
emissions reporting prior to that date. As a result, IPPU (in this case SF6) emissions information is not available
from 2005 through 2010. Options for estimating IPPU emissions from Broadcom that have been considered
include:
• Calculating an average from 2011 to 2018 data and using this value back to 2005;
• Holding the 2011 value back to 2005;
• Using data from 2011 to 2018 to create a backwards linear estimate of IPPU emissions to 2005; or
• Seeking to identify a proxy indicator with which to correlate Broadcom’s IPPU emissions. Further research
would be necessary to establish how robust this estimate could be.
Approach 2005 Baseline
MTCO2e
2018 MTCO2e Percent below
2005 baseline
Confidence
Current inventory 2,276,172 1,963,919 -14% High
Integrated inventory with
known IPPU data from
2011-2018 (no IPPU
included for 2005) 2,276,172 2,121,857 -7% Low
Using an average from
2011-2018 data for 2005-
2010 2,443,608 2,121,857 -13% Low
Holding the 2011 value
back to 2005 2,309,559 2,121,857 -8% Low
Creating a backwards
linear estimate from
2011-2018 data 2,121,857
Approach not supported
by data trends
Correlating SF6 data to a
proxy indicator to
estimate 2005-2010 Unknown 2,121,857 Unknown Unknown
Because the reported SF6 emissions from 2011 to 2018 do not follow a linear trend, estimating the six prior years
through any of these approaches is challenging. The significant differences in percent below baseline depending
on approach demonstrate the uncertainty that could be introduced with these methods. For this reason, staff do
not recommend Option 4, the single integrated inventory.
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Fort Collins' work and progress
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