Baseline Protection
Greenhouse Gas Reporting and Disclosure: Key Elements of a Prospective U.S. Program
Baseline Protection and Credit Trading
It is not known when a program to limit emissions of GHGs will be established in the United States or what the design of such a program will ultimately be. Despite these uncertainties, it is important to move forward with GHG reductions, given the long atmospheric lifetimes of greenhouse gases. To stimulate voluntary reductions of GHG emissions today, a GHG reporting program should provide “baseline protection” for companies that have already taken action or are planning to take action to reduce their emissions. These entities should be assured that — in the event of future controls on GHG emissions — they would receive credit for reductions achieved voluntarily. The extent and form of such credit would, of course, depend on the design of the ultimate GHG control program.12
Baseline protection from the first year of reporting and onward should apply to all participating entities that are in compliance with program requirements, with adjustments made to account for acquisitions, mergers, and other changes in the entity’s operation. An entity’s “baseline” would be emissions reported during its first year of reporting under this program, unless it chooses to select an earlier base year for which there is credible and verifiable information on GHG emissions. Those selecting an earlier base year would follow the procedures discussed below.
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