Climate Change: EPA and DOE Should Do More to Encourage Progress Under Two Voluntary Programs

In our April 2006 report, we recommended that DOE develop a system for tracking participants progress in completing key steps associated with its Climate VISION program. While DOE agreed that a tracking system would prove useful in helping it gauge the progress being made by the partners, and initially agreed to develop such a system, they found methodological challenges for tracking the individual progress of each partner, and indicated that they were unable to develop the originally envisioned tracking system. However,DOE, through its contractor, did develop a methodology that tracks progress toward the collective overarching goal by the partners. While this methodology does not enable the agency to ascertain whether individual participants are meeting program expectations in a timely manner, it does provide a comparable metric that relies on reproducible, widely available data. DOE also agreed to produce annual updates using this methodology for the entire program until the emission intensity goal has been met, or until a final analysis is completed. In addition, they are providing the public with information to help evaluate the effectiveness of the voluntary program. The Progress Report 2007 is available on DOE's website at http://www.climatevision.gov/sectors/progress_reporrt/pdfs?CV_Progress_Repoprt_Final_Report.pdf. In December 2007, DOE's contractor issued a Memo describing its Industry and Power Group GHG Tracking for Voluntary GHG Programs that provides a variety of time series data. This public information provides additional incentives to improve the accuracy of participant reporting. In conclusion, while DOE did not establish the specific tracking system GAO recommended, its actions collectively address the intent of GAO's recommendation.

In our April 2006 report (GAO-06-97), we recommended that EPA develop written policies establishing the consequences for not completing its Climate Leaders Program, a voluntary program that encourages firms to set emission reduction goals to reduce greenhouse gas emissions. We reported that EPA had not developed a written policy on what to do about firms that are not progressing as expected. Following our report, EPA developed a written policy regarding the agency's expectations of each program participant in the Climate Leaders Program and the consequences for failure to meet the program's requirements. The Policy on Conformance with Program Requirements, which is available on the agency's Web site (http://www.epa.gov/climateleaders/partners/conformance.html), was posted in February 2010. The Policy establishes key milestones for both Climate Leaders Partners--large commercial and industrial companies--and Small Business Network members. For example, it states that Climate Leader Partners must complete both base year reporting and a goal proposal no later than 24 months after the join date or EPA will automatically remove the Partner from the program. In another example, the Policy states that each Small Business Network member must submit its GHG emission reduction goal to EPA no later than 12 months after the join date. According to the Policy, if a member fails to submit its goal on time EPA will contact the member to inquire about that delay and may send a letter to the member stating that the member has 3 months to submit the goal. The Policy states that if the member still fails to submit its goal within 3 months EPA will automatically remove the member from the program.