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Commute conundrum

Should emissions from employee commutes be included in company GHG inventories?

Posted by Guest author (Guest Contributor) at 11:08 AM on 27 Mar 2008

The following is a guest essay by Kevin Luten of UrbanTrans, a sustainable transportation consulting firm working in Australia and the United States. He is based in Melbourne.

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When businesses dip a toe in the rising sea of corporate action on climate change, the first box they check before diving in involves tabulating their own greenhouse-gas inventory. In getting your corporate house in order, the first step is defining where your yard ends and your neighbor's begins.

The good news: There is a clearly accepted international standard providing guidance to companies sorting "what's in" and "what's out" for their GHG inventory. The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard is the playbook everyone is working from.

The bad news: Some issues are more clearly defined in the guidance than others, leaving individual companies to sort out their own best way forward.

Emissions from employee commutes are one such gray area. In these early days, how leading companies come down on this issue is critically important in setting a precedent. The GHG Protocol does provide general guidance on this issue, but more specific direction is needed.

Transport Emissions

In the United States, over 20 percent of GHG emissions are from road transport. While plug-in hybrids or other advancements may someday allow us to bask in the glow of greener traffic jams, today's commuter is a major contributor to the country's GHG tally.

In establishing a GHG inventory, emissions from sources such as combustion of fuel in furnaces owned by a company are a black and white area. They would be referred to as a "Scope 1" direct emission, and are a mandatory part of a company's GHG inventory.

Other emission sources, such as those produced by employees commuting to and from work (in vehicles not owned by the company), fall into a murky gray zone known as "Scope 3" indirect emissions. Individual companies are left to decide whether such emissions are in or out.

What to do?

With employee commutes, it is tempting to assume that these are not a business responsibility. After all, an employer can't control whether Tim from HR rides the bus to work. In fact, it's a gray area, according to the GHG Protocol, which offers broad guidance to companies working through this issue.

The guidance recommends that companies account for Scope 3 emissions based on the "relevance and significance" of these emissions to the company's overall operations or business goals, suggesting that such emissions may be deemed relevant if they meet any or all of the following four criteria:

  1. Relative size: They are large (or believed to be large) relative to the company's Scope 1 and Scope 2 emissions.
  2. Risk: They contribute to the company's GHG risk exposure.
  3. Stakeholder concern: They are deemed critical by key stakeholders (e.g., feedback from customers, suppliers, investors, or civil society).
  4. Company influence: There are potential emission reductions that could be undertaken or influenced by the company.

A key test for Scope 3 indirect emissions then is the significance of these emissions in relation to other Scope 1 and Scope 2 sources. If a Scope 3 area (such as employee commuting) accounts for a significant portion of the organization's overall emissions, then the guidance suggests the company should include these within its GHG inventory.

Given these guidelines, service sector businesses, government organizations, and most other knowledge-based entities (which likely have very few, if any, direct emissions) are the groups that must take the closest look at Scope 3 indirect emissions, as they are more likely to come from relevant and significant areas central to the core operation of the organization. For a knowledge-based business, employees are at the very core of the organization's operations, and how they get to and from work matters.

The "company influence" factor is most interesting. Essentially, the GHG Protocol specifies that the key lies in company influence rather than control over an issue. So while an employer can't control whether Tim from HR rides the bus to work, there are indeed many factors fully within an employer's control that significantly influence Tim's decision. Does the company offer Tim a free parking space at work, or do they offer free or discounted bus passes? Do they offer flexible schedules to better accommodate public transit schedules? Did they consider transit accessibility when locating the business? These and other employer decisions are factors proven to directly impact employee commute behavior.

Because this is a gray area, however, many companies seem to be placing employee commutes outside their GHG inventories out of convenience, rather than out of a sound reading of international guidance. Too often, it appears these decisions are based on a perception that including employee commutes would place too large a burden on overall GHG reduction strategies (or offset purchase costs). While some may still sponsor generous employee commute programs, if these are not part of their GHG inventory process, the programs will always be second-tier considerations.

As one important example, the World Resources Institute, co-authors of the GHG Protocol, includes employee commutes in its GHG inventory. The WRI conducts annual surveys of its employees to understand travel patterns and offers a full array of company-sponsored programs to reduce transport-related emissions from these activities.

Should others follow suit and establish a clear precedent for best practice on this important issue?

locate transit close to workplaces

"Did they consider transit accessibility when locating the business?"

The realistic way to reduce commuting GHG is to locate workplaces close to the type housing that workers desire.  Moving corporate headquarters to the suburbs accomplishes this.  But environmentalists seem to recoil in horror at the concept of sprawl - or population and workplace dispersion.  In fact, though, geographic dispersion of workplaces allows many more workers to live close to their jobs.

Transit systems have been designed to benefit central business districts.  Those systems rarely reflect the desires of both workers and employers who have been rejecting central business districts for decades.  Worse, because the layouts of tracks are planned many years in advance of construction, rail-based transit systems cannot adapt to changes in growth patterns.

The solution to increasing transit usage lies not in locating workplaces close to CBD-oriented transit.  Rather, transit systems need to be flexible enough to locate close to workplaces in evolving development patterns.  That's why bus transit - with it's far lower capital costs per seat mile - should be the backbone of large cities developed after the 19th century.

It Is Not Their Business

This opens a whole can of interesting worms.

Suppose someone lives in one area, loses their nearby job, and has to look for a job 20 miles away? Is it fair for a company to say they can't hire them because it will increase the company's carbon emissions? It basically puts another barrier between a person who needs a job and employer who might want to hire them.

It could drive up the cost of housing around certain employers, making sure only the "right" sort of people live there.

What happens when the company does decide to move its operations to Mexico? All those people now have to commute to different places, if they're lucky to find a job at all. Or do you expect them to abandon their houses, and community, and move constantly to chase after jobs? The company wins and people get screwed.

It might be very convenient for a company to avoid certain workers by just moving the operation beyond an environmentally acceptable means of getting there. Sorry, we're not going to hire you because you live too far away... nothing to do with the fact that we just don't like your kind.

It will severely reduce opportunities for people to find good jobs and employers to find good people.

If you're going to permit a company to consider commuting as far as GHG emissions are concerned, will you also allow them to consider the rest of an employee's life style. Suppose a person commutes, but otherwise does a lot to reduce their GHG emissions... maybe they are vegetarians. Do they get to transfer that to the corporate books? I mean, a commuting vegetarian who puts photovoltaics on his house, buys organic food, and doesn't waste energy on a manicured lawn might be a better deal than the guy who lives right next to the corporate office, cranks his air conditioning down to 65F all summer, eats mostly meat, and drives 50 miles to the "country" each weekend to tear up the landscape with his four-wheeler for recreation.

Will the GHG emissions transferred to the corporation reflect the exact vehicles driven by employees? Suppose someone has an electric car powered by electricity generated by a nuclear power plant? A guess he still gets to commute to work... and will probably become a lobbyist for nuclear power.

Just a spontaneous, not very well thought out response. But it seems the unintended consequences could be rather unpleasant for everyone.

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