21 December 2015 Federal GHG Regulations Renewable Fuel Standards and Biofuels Share on: DOT Strategic Sustainability Performance Plan As described in this previous post, the Obama Administration issued Executive Order 13693, directing key federal agencies to develop “Strategic Sustainability Performance Plans” that explain how they will achieve specified sustainability goals and reduce direct emissions of greenhouse gases by 40 percent by 2025. As directed by EO 13693, the U.S. Department of Transportation (DOT) released its Strategic Sustainability Performance Plan in June 2015. The plan describes DOT’s progress in reducing greenhouse gas emissions and achieving related sustainability goals to this point and outlines the Agency’s plan for complying with EO 13693 going forward. The chart below depicts DOT’s progress in reducing greenhouse gas emissions from 2008 through 2014 for direct (Scope 1) and indirect from consumption of purchased electricity (Scope 2) emissions. DOT divides the emissions reduction and sustainability goals of EO 13693 into ten focus areas: greenhouse gas emissions reduction, sustainable buildings, fleet management, water use, pollution and waste reduction, sustainable acquisition, electronic stewardship, renewable energy, climate change resilience, and energy performance-based contracts. DOT then identifies its top five strategies for furthering Agency progress in each focus area. For each strategy, DOT established specific metrics for measuring its success and milestones to achieve within the next 12 months. Three of DOT’s key planned strategies for climate issues are described below. 1. Strategies for reducing greenhouse gas (GHG) emissions: DOT reports it will reduce agency-wide GHG emissions by employing best management practices, completing Energy Independence and Security Act of 2007 (EISA) Section 432 energy audits, and continuing to implement cost-effective energy conservation measures. Under Section 432 of the EISA, federal agencies are required to identify "covered facilities" that make up at least 75 percent of their total facility energy use and perform an energy evaluation of each covered facility once every four years to identify potential energy efficiency and conservation measures. DOT will complete its remaining Section 432 audits and establish internal working groups to identify and implement practices that support improved data on energy conservation and efficiency within the next 12 months. DOT also plans reduce grid-supplied electricity consumption by improving or upgrading motors, boilers, heating, ventilating, and air conditioning, chillers, compressors, lighting, and other electricity-consuming equipment. Over the next 12 months, DOT plans to: (1) award two or three performance-based contracts for such projects; (2) install new chillers at the U.S. Merchant Marine Academy; and (3) complete lighting projects at several sites. Lastly, DOT will seek to reduce business travel (air and ground) through a range of efforts including travel budget restrictions and installation of technology to facilitate remote meetings. 2. Strategies for increasing use of renewal and alternative energy: The plan also outlines strategies for increasing DOT’s use of renewable and alternative energy. DOT will install agency-funded onsite renewable energy generation where feasible. In the next 12 months, DOT will evaluate the feasibility of installing renewable energy at seven sites and will implement at least three renewable energy projects. Additionally, DOT will award at least two performance-based contracts that include the installation of renewable energy. Where onsite renewable energy generation is not feasible, DOT will prioritize the direct purchase of renewable energy in combination with Renewable Energy Certificates (RECs). In the next 12 months, DOT will utilize a combination of direct renewable electricity purchases and REC purchases to ensure that at least 10 percent of the total electricity consumed by DOT annual comes from renewable sources. 3. Strategies for improving climate change resilience: DOT will implement a number of programs to improve climate change resilience. DOT plans to incorporate climate preparedness and resilience into planning and implementation guidance documents for agency-implemented projects. To ensure that its climate adaptation and resilience policies always reflect the best available climate change science, DOT will conduct annual reviews of relevant programs and operations along with annual reviews of climate change science literature to identify opportunities to update or modify policies and programs. Where applicable, DOT will evaluate the effectiveness of any funds targeted for enhancing climate resilience. DOT will also evaluate existing external programs and policies, such as grants, loans, and technical assistance, looking for opportunities to incentivize planning for climate change. The plan also identifies strategies for: promoting building energy conservation, efficiency, and management; improving fleet and vehicle efficiency and management and reducing fleet-wide per-mile GHG emissions; ensuring sustainable acquisition; and reducing waste. Additionally, the plan provides for periodic review to assess progress and evaluate necessary plan revisions. The plan acknowledges the challenges DOT will face in achieving the goals set out in EO 13693. For instance, it notes that “[a]chieving reductions going forward may become more difficult and directly compete with mission requirements since DOT has implemented most no- or low-cost tactics.” The plan outlines ambitious strategies that DOT plans to refine over time.