Department of Interior Releases Strategic Sustainability Performance Plan for 2015
The Department of Interior (“DOI”) has released its
Strategic Sustainability Performance Plan (“SSPP”) for 2015. The agency issued the report pursuant to a series of related executive orders, beginning with
E.O. 13514 in October 2009, that require certain agencies to increase efficiency and improve their environmental performance. The executive orders require each agency to annually issue an SSPP that describes the agency’s environmental goals, its strategies
for achieving those goals, the progress it has made to date, and its planned actions to achieve the goals. The environmental goals must include, but are not limited to the reduction of greenhouse gas (“GHG”) emissions.
Executive Order 13693, which President Obama signed in March 2015, is the most recent executive order regarding federal agencies’ environmental goals and the content of the SSPPs they must issue. It sharpened the agencies’ focus on GHG emissions by obligating “principal” federal agencies to cut their carbon
dioxide output by an average of 40 percent compared with 2008 levels by 2025. The SSPPs of such principal agencies, including DOI, must now incorporate that goal and describe how the agency will meet its emissions targets over the next decade. Previous executive orders required agencies to set GHG emissions
targets, but did not impose the 40 percent reduction that E.O. 13693 has mandated. For more background on the SSPPs, please see this
An SSPP generally seeks to integrate environmental goals within an agency’s operations and ultimately reduce its GHG emissions. Although DOI is responsible for leasing federal land to oil and gas producers, the SSPP does not address the GHG emissions of oil and gas operators. Instead, the SSPP focuses on DOI’s own environmental
performance, rather than the environmental impact of lessees’ operations. The SSPP is organized around the agency’s environmental goals, which include the reduction of GHG emissions, pollution prevention, sustainable procurement, and more.
DOI asserted that it reduced its GHG emissions by 18.8% as compared to 2008, which exceeded its goal of a 9% reduction by 2014. It reported that teleworking and reduced business travel were especially effective emission-reduction measures, and suggested DOI could further reduce
its emissions by educating managers about the benefits of teleworking and managing a mobile workforce. Furthermore, DOI consumed 77,069 MWh of renewable energy through on-site generation and purchasing renewable energy certificates. This represents approximately 13.3% of the agency’s energy use, exceeding its
goal of 7.5%. As a result, the agency’s GHG reductions are ahead of schedule. The chart below depicts DOI’s GHG emissions since 2008.
DOI reports that its efforts to reduce its GHG emissions include several initiatives to reduce the resource intensity, and improve the energy efficiency of its operations and assets. For example, DOI’s fleet management strategies improved the overall energy efficiency of its fleet,
which reduced the fleet’s petroleum consumption by 19% compared to 2005. DOI also increased its use of alternative fuels by 90% and reduced the number of vehicles in its fleet by 10% over the same time period. In addition, the agency has renovated some of its buildings to achieve net-zero energy consumption and
begun to procure more energy efficient laptops, desktops, monitors, and data center equipment.
DOI reports that it will be challenged to maintain the pace of its GHG reductions. The agency reported that “many of the low-hanging fruit projects have been implemented” because of its longstanding efforts to reduce energy consumption. To achieve its emissions goals by 2025, the agency must
invest in projects with a longer return on investment, such as renewable energy components and building renovations to ensure high performance buildings. The agency’s real estate portfolio makes such projects particularly challenging. DOI operates facilities in many remote locations, such as the Midway Atoll or the
Palmyra Atoll. As a result, “it remains a challenge to attract the interest of energy service companies due to [DOI’s] small facility size, remote locations, special requirements for historic properties and unique bureau missions.” The agency also noted that its emissions tended to rise in conjunction with its
funding levels, since more funding led to increased staffing levels, commuting, and business travel. On the other hand, the personnel resources working to achieve the agency’s environmental goals were flat or declining. This suggests that the agency may need to dedicate a greater proportion of its personnel
resources to environmental matters to achieve further emissions reductions.
at 12/16/2015 5:00 PM