Can you imagine how the authors felt? In each of these cases, the authors are trying to do the right thing under an increasing sense of urgency. They are dealing with high levels of uncertainty, insufficient data and sometimes conflicting information from different sources. Everybody appears to have different ways of dealing with this uncertainty. In one case, the authors attempt to ignore the uncertainty by trying to sound like there isn’t any. For the majority, you can almost hear them thinking: Are we being too conservative in our emissions calculations? Are we being too conservative in the credits that we are potentially granting? How much of a financial burden is acceptable for data collection? Is insufficient or incorrect data worse than increased monitoring requirements? How much is too much to ask for monitoring, how much is too little?
EPA is asking readers to please comment, please let us know if we got this even remotely right. In almost all cases there is a willingness to default to what somebody else has done — if the International Panel on Climate Change (IPCC) says so it must be right. Where is the boundary — when do we start counting and where to we stop? Are we giving out rewards or punishing?
This reminds me in some ways of early environmental legislation on air pollution. Before the Clean Air Act in 1970, which provided us with enforceable limits on air pollution and punishment for noncompliance, we had the Air Pollution Control Act of 1955 and the Clean Air Act of 1963. The first provided funding for research: Do we really have air pollution, and if so, what does it consist of and where does it come from? The second provided funding for research on techniques to monitor and control air pollution. Some 15 years after the first regulation we got one that had the power to actually reduce air pollution. By then we had solid ideas of what compounds we were concerned about, how to measure them and alternatives to reduce their emissions.
Here we are trying to roll all three (gathering background information, determining how to monitor and control, and finally, emissions limits) into one in a 2-year time frame. And we are doing this with a big handicap. For air pollution, the regulations that had actual enforcement capability were made after the research had been at least partially done. Here we are coming in after eight years of an administration that didn’t recognize that this was a real problem and certainly wasn’t funding research on much of anything except perhaps homeland security. They didn’t seem to recognize that climate change could fundamentally affect our security. So we are trying to regulate stuff that we don’t fully understand or know how to measure.
Let me give you an example. I was looking to find information on nitrous oxide emissions from burning biosolids. There is an IPCC default value of 0.9 kg N2O/dry metric ton of biosolids. Where did that come from? A couple of papers with single point measures. What is dry and what is wet? Not really defined. What about different types of combustion? Not really discussed. What about co-combustion? A paragraph, but no data. I was pointed in the direction of one excellent paper in the Japanese Journal of Chemical Engineering, where continuous readings of fluidized bed mono combustion facilities were taken on a number of facilities and their answer was 1.5-6.4 kg N2O/dry Mg biosolids (Suzuki et al., 2003). A bit of a difference I would say from 0.9 kg. Particularly as N2O has 296 times the global warming potential of CO2.
ACT, BUT KEEP GATHERING INFO
So with this uncertainty, what approach is the best for getting things done? EPA seems to be getting this right. In its document, it says when it isn’t so sure, and says that it wants more information. It explains why it has opted for the approach that it is proposing. It compares the chosen approach with the alternatives to explain why the one selected is best. By asking for comments and input, EPA is hopefully going to get some cooperation and good ideas. The people that operate facilities will have a better understanding of variability and uncertainty than EPA. This will potentially allow EPA quickly to gather data that can then be used to fine-tune regulations. It also may potentially help to provide information on best management practices for existing technology that will reduce emissions until alternatives are identified.
The one thing that I would suggest is for EPA to ask for data from a wider range of sources and a wider range of activities. The more data that you have, the better off you are. The IPCC is a great group and has provided invaluable leadership for quantifying and mitigating climate change. EPA has relied on IPCC in developing its approach. However, IPCC is trying to provide solutions for the world, and one solution doesn’t generally fit all. For example, the IPCC has a standard default value for N2O emissions from fertilizer, compost and biosolids amended soils. All the same, all over the world. EPA has decided not to deal with this at this point saying: “Activity data collection and emission factor development necessary for emissions calculations at the scale of individual reporters can be complex and costly.”
This would be an excellent time, during its initial effort to quantify emissions, for EPA to set up programs to collect the data. The data will allow for smarter regulations and even for information on best management practices. We all want to do something, but we need options on what is best to do, in order to change our practices. So this is an excellent first step for EPA, but get more information so that the next step can be a giant one.