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Compliance with the EPA’s MRR Standard

Posted By William Newman, January 13, 2011 at 2:09 PM, in Category: Sustainability

(Taken from the View from C-Level blog, January 11, 2010).

Today’s sustainability landscape looks more like a sprawling  metropolis with no building design than it does well-intentioned  regulations threaded together to provide transparency and visibility to  consumers, governmental agencies, and investors. The University of  Oregon Sustainability Leadership Program tracks  nearly 50 standards, methods, regulations, and approaches that an  organization, based on its particular operating location, industry  segments, and communities, may be obliged to follow and report on.

The immediate reporting introduction for those companies operating in the US is the Environmental Protection Agency (EPA) Mandatory Reporting Rule (MRR, defined in 40 CFR 98) which is designed  to collect greenhouse gas (GHG) information, including specific  emissions from specific industry participants and a list of other  industry segments that may apply. Unless your company is squarely in the  crosshairs of the MRR filing requirements — called “all-in” source  category companies, such as aluminum manufacturing — it may be difficult  to determine your actual reporting requirement. Further complicating  the lack of clarity is the impending deadline of January 30, 2011, to  submit certification of representations to the EPA. The EPA has created a  portal called the electronic Greenhouse Gas Reporting Tool (e-GGRT),  which organizations can use to capture their initial GHG tallies and  provide them, as needed, to the agency.  According to the EPA Web site,  the mandatory filing window for “all-in” source category companies  begins on March 31, 2011. It also lists industry segments considered  “all-in.”

As such, it is important for organizations, particularly for those  “all-in” source category companies and those organizations operating in  their supply chains, to begin to gain visibility into their carbon  footprint. This provides visibility into their specific position in the  exposure of dangerous emissions as well as the use of natural resources  and toxins in their day-to-day operations. Once this information is  known, the organization and its supply chain can begin proactive  measures to address reduction of GHG emissions and its overall carbon  footprint. I’ll start by explaining some ways you can assess  sustainability impacts in your organization, and then go into how SAP  Carbon Impact helps you monitor these impacts with various on-demand  reporting tools.

Assessing Sustainability Impacts in the Organization

Reduction in carbon emmissions is not only good for the environment,  it is required under the guidelines of the EPA MRR. Further, you can  obtain marketing and investor management benefit from the introduction  of sustainably conscious business practices in the organization. These commonly assessed and baselined components in sustainability assessments include:

  1. Energy: The movement towards 100% renewable energy, including  self-developed (e.g., grid-neutral) sources owned by the company
  2. Industry: Engagement in the participating industry dialogue to help the industry as a whole transform into new business practices,  both green and profitable
  3. Products and services: The focus on long-term products and  services that are profitable, reusable, and meet real market needs  (versus passing commercial fads)
  4. Materials: Developing sources of inputs and materials that are reusable, locally grown or produced (to reduce transportation carbon effects), and sustainably harvested
  5. Waste stream: Using life cycle analysis (LCA) techniques, can a  closed-loop process be identified in which the inputs going into  the product can be renewably disposed, creating a zero-waste scenario? For example, can the outputs be used as inputs to another commercial process in renewable form?
  6. Community and economy: Doing all of the above in a economically  viable and efficient manner over time, so that the organization can provide employment and economic benefit, support local communities and charities, and be a good corporate neighbor

Many calculators are available to determine the relative position of  organizations against multiple key performance indicators (KPIs) and  emerging industry baselines. You can use SAP Carbon Impact OnDemand as  part of the assessment process to evaluate the current position of an  organization’s carbon footprint as well as to provide a benchmark  monitoring tool to assist the organization in achieving reduced GHG  emissions.

For a full description of the Carbon Impact OnDemand solution, please visit the SAP Expert site here (registration  required). The SAP Sustainability Executive Advisory Council (EAC) is a  community focused on sharing of best practices and co-innovation in the  area of sustainability. To learn more information and register for  membership, visit the Sustainability EAC’s site.  (Many thanks to SAP Experts for permission to abstract this article.) Visit me on the Insider Learning Network or on Twitter (william_newman).



Category: Sustainability
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Written by William Newman



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