Bloomberg Law quoted Of Counsel Leah Dundon (Washington, DC) in Big Task Awaits Federal Agencies in Tracking Carbon Footprints. The article discusses new White House instructions directing federal agencies to track and report downstream carbon emissions down to employee travel time.

The rules, issued by the Council on Environmental Quality, are expected to be challenging to follow for larger federal agencies. They will also require agencies to set target greenhouse gas (GHG) emissions from sources these agencies don’t directly control.

Leah commented that “indirect emissions will be difficult to measure accurately” and that “it’s potentially a complex and huge undertaking, and will be more so for larger organizations, including federal agencies.”

She also said that “the data needed to make a Scope 3 emissions assessment often isn’t under an agency’s control, and the available data can be hard to verify.” The U.S. Environmental Protection Agency has provided emission factors to allow for estimatations in some categories, but accuracy will be challenging.

In addition to this information being difficult to verify, “it is not clear whether the data is useful in informing emissions reduction strategies.”

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