Greenhouse Gases Mandatory Reporting

United States Environmental Protection Agency

In 2007, the Supreme Court ruled that greenhouse gases (GHG) are air pollutants covered by the Clean Air Act.

In turn, the US EPA signed a proposed endangerment and cause or contribute findings for GHG under Section 202(a) of the Clean Air Act. US EPA then held a 60-day public comment period, which ended June 2009. Over 380,000 public comments were submitted during the comment period.

In September 2009, the US EPA mandated all large facilities emitting over 25,000 tons of GHG per year shall establish a Greenhouse Gas Monitoring Plan and annually report GHG emissions from stationary sources, beginning in 2011.

UCSF’s Parnassus campus is subject to the above regulations and pursuant to those regulations, Environmental Programs keeps a GHG inventory for stationary sources. The first annual report was submitted in June 2011.

California Air Resources Board

Pursuant to California’s Global Warming Solutions Act of 2006 (AB32), UCSF is required to report greenhouse gas (GHG) emissions from stationary sources at the Parnassus Campus. GHG emissions are reported annually to CARB for the six legally recognized GHGs:

• carbon dioxide (CO2),
• methane (CH4),
• nitrous oxide (N2O),
• hydrofluorocarbons (HFCs),
• perfluorocarbons (PFCs), and
• sulfur hexafluoride (SF6)

UCSF equipment currently covered by this reporting requirement include gas turbines, boilers, refrigerants, and diesel engines.

Annual reports are uploaded to the CARB website and verified by a state certified third party. The first year of reporting began in April 2009 for the 2008 calendar year, with third party verification beginning in April 2010 for the 2009 calendar year.

This annual report is a collaborative effort between Environmental Programs, Facilities Management, and Parnassus Central Utility Plant engineering staff.

Cap & Trade

Cap & Trade is a greenhouse gas curtailment mechanism based around supply and demand. In theory, each regulated facility will be required to secure credits equivalent to their annual GHG emissions from stationary sources. Each year, the Cap & Trade administrative body will artificially lower the total number of available credits by a prescribed amount, thereby increasing demand (and cost) of said credits until it becomes financially beneficial to simply reduce your facility’s GHG emissions (carbon footprint).

Carbon credits may be auctioned on the open market and “offsets” may be used to supplement a portion of a facility’s annual obligation.

Both the Federal and State governments have proposed various versions of the Cap & Trade program, neither of which have been released, due to political and legal challenges.

Sustainability- Climate Change Work Group

Environmental Programs is an active participant in UCSF’s sustainability effort. The Climate Change Work Group (CCWG) tasked with promoting and encouraging carbon neutrality at UCSF with the following goals:

• Achieve 2000 emission levels by 2014
• Achieve 1990 emission levels by 2020
• Join the California Climate Action Registry or The Climate Registry
• Complete an annual greenhouse gas emissions inventory

The CCWG is instrumental in preparing the UCSF Climate Action Plan, which identifies / calculates the university’s current activities / impacts, outlines sustainability efforts, and establishes numerical targets as they relate to greenhouse gas emissions.

The bulk of UCSF’s GHG emissions are the result of stationary combustion to generate heat and power. Natural gas is estimated to represent as much as 55% of UCSF’s total GHG emissions.

Furthermore, UCSF GHG emissions have drastically increased since 1990 and are now estimated to represent ~ 1.5% of the City of San Francisco’s total GHG emissions of 9.7 million metric tons of CO2e.

This is sharp increase in GHG emissions is largely attributed UCSF’s continued physical expansion and the decision to produce our own electricity at the Parnassus campus. With strong growth realized in the last 20 years and more growth planned for the next decade, UCSF’s goal to reach 1990 GHG emission levels is no small task. Current projections detailed in the Climate Action Plan indicate that a significant university wide effort and investment will be required to reach our 2020 goal.

The CCWG continues to look for improvement projects and operational methods that will allow UCSF to close the current gap by 2020.