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(3) each is credited by EPA as substantially reducing greenhouse gas emissions. Appendix I provides funding levels, the number of participants, and other information about each program.

The Green Lights Program is designed to encourage organizations to
voluntarily adopt energy-efficient lighting technologies, such as compact
fluorescent light bulbs and electronic ballasts. EPA provides information
intended to encourage the adoption of these technologies. The Source
Reduction and Recycling Program is designed to reduce the volume of
solid waste produced and sent to landfills. Under the program's WasteWise
element,* EPA signs up businesses that agree to voluntarily decrease the
amount of waste they generate and to increase the amount of waste they
recycle. Under the program's Unit-Based Pricing element, local
communities agree to charge residents for waste disposal on the basis of
the amount of waste they generate.

The Coalbed Methane Outreach Program is designed to encourage coal
mines and related industries to recover and use methane that would
otherwise be emitted. The State and Local Outreach Program is a
foundation program, designed primarily to raise awareness about climate
change and provide technical support to state and local agencies and
nonprofit organizations in analyzing and developing cost-effective
response strategies, not to achieve short-term reductions in greenhouse
gas emissions. The program also funds demonstration projects designed to
test innovative strategies for reducing emissions and examine the impact
of climate change on the states.

EPA establishes annual program targets for the programs, such as the volume of reductions in greenhouse gases (except for foundation programs, as noted above) and the number of participants. It tracks progress against these targets, relying primarily on reports from the programs' participants. However, EPA does not independently verify these reported reductions.

'EPA refers to it as Waste WISE.

B-276994

Greenhouse Gas
Reductions Reported
by EPA Are Not
Limited to Program
Effects in Two of the
Four CCAP Programs
We Examined

Green Lights Program

Efforts to improve energy efficiency, increase recycling, and achieve related goals have been under way for years. These long-standing efforts make it difficult to measure the programs' "net" reductions—those that result only from CCAP programs-as compared with total, or "gross," reductions-those that result from CCAP programs as well as from other, nonprogram factors. EPA officials told us that measuring the net reductions that are strictly due to the results of CCAP efforts is difficult."

According to EPA, 2,308 organizations were participating in the Green Lights Program as of February 1997. These organizations committed to upgrade the lighting in 6 billion square feet of floorspace, about 9 percent of the national total, according to EPA. Through fiscal year 1996, Green Lights participants reported upgrading the lighting in 1.3 billion square feet of floorspace, resulting in greenhouse gas reductions of 0.6 MMTCE. Although some of the reported reductions may be the result of influences from outside of the Green Lights Program, EPA did not attempt to measure the program's "net" benefits. Officials said that they believed that any reductions that resulted from other factors were likely offset by the reductions achieved by the nonparticipating organizations that were influenced by the program but not reported to EPA.

According to the representatives of seven former participants we spoke with, the program had a positive impact on these organizations' efforts to achieve energy savings from lighting technology. When we interviewed officials at these organizations that had completed their participation in the Green Lights Program, representatives of all seven said that they were pleased with the program. For example, some representatives said that they viewed the data provided by EPA on the benefits of specific lighting technologies as being valuable and objective.

The reductions reported by EPA could be overstated if some Green Lights participants undertook at least some of their lighting upgrades because of nonprogram factors. Four factors suggest that some upgrades were made because of nonprogram factors.

First, according to a 1992 survey of commercial buildings, a substantial amount of floorspace was upgraded before the Green Lights Program was

'According to EPA officials, in a forthcoming report the administration will provide information on its estimates of the net greenhouse gas reductions resulting from the climate change programs. The report is scheduled to be issued in July 1997.

B-276994

well established. The national survey of commercial buildings was conducted by the Department of Energy's Energy Information Administration (EIA). The survey found that 43 percent of commercial floorspace had lighting conservation features (such as occupancy sensors and time clocks) and that 22 percent of the floorspace had undergone an energy audit (which can identify opportunities for saving energy) in the previous 5 years.

Second, financial incentives that were available during the early to mid-1990s may have induced some organizations to install energy-efficient lighting. Officials of the Edison Electric Institute, an electric utility trade group, estimated that 80 to 90 percent of its members offered financial incentives during that time period to encourage their customers to install more energy-efficient lighting. By offsetting some of the costs of lighting upgrades, such assistance provides an incentive to adopt energy-efficient lighting. In fact, Green Lights participants reported to EPA that they had received $143 million in such rebates through fiscal year 1996.

Third, some of the reductions attributed to the Green Lights Program were achieved by companies involved with lighting products, which could be expected to install energy-efficient lighting without the program. Of the 2,308 Green Lights participants, 593, or about one-quarter, were classified as "allies," that is, companies that manufacture, sell, and install lighting products. The reductions reported by these companies account for about 6 percent of the program's total. However, such companies could be expected to install energy-efficient lighting even without the Green Lights Program, given their knowledge of the benefits of this technology.

Finally, most of the representatives of organizations we spoke with about lighting upgrades, some of whom had participated and others who had not, told us that they would likely have made some of the upgrades without the program. When we spoke with the representatives of seven organizations that had completed their affiliation with the program, five of the seven stated that they would have done some or all of the upgrades without the program; the other two stated that they would not have done the upgrades without the program. In addition, we spoke with representatives of two major national corporations that did not participate in the program. Both companies told us that they had undertaken major lighting upgrades in the past few years without EPA's assistance.

This survey was conducted shortly after the Green Lights Program was implemented. See Commercial
Building Characteristics 1992, pp. 9-16. Energy Information Administration (DOE/EIA-0246(92),
Apr. 1994).

B-276994

State and Local Outreach
Program

Green Lights Program officials noted that they did not attempt to offset the reported reductions that may have been attributable to these other factors because they believe the program has offsetting impacts above and beyond the reductions reported by the participating organizations. For example, they noted several instances of nonparticipating companies that they believe undertook lighting actions as a result of information furnished by the Green Lights Program. However, they said they had not attempted to quantify the extent of the uncounted reductions by nonparticipants.

According to EPA, 29 states and Puerto Rico have conducted inventories of their greenhouse gas emissions, 42 cities are developing action plans, and 7 demonstration projects have been selected for evaluation. Program officials said that although the program does not have a greenhouse gas reduction goal, it resulted in a reduction of 0.8 MMTCE in 1996.

Most of the reduction, about 0.7 MMTCE, was attributed to one
demonstration project, called the Planet Protection Center. The main goal
of this joint project between EPA and the approximately 46,000-member
National Retail Hardware Association was to reduce residential energy use
by promoting energy-efficient heating, lighting, and plumbing products.
The participating retailers received materials to use in their stores to
inform shoppers and salespeople, at the point of sale, about the benefits of
buying energy-saving products. EPA officials said they initially estimated
that 8 million households could reduce their energy consumption by an
average of 10 percent because of the program. They said that to account
for the possibility that market penetration might be less than 10 percent,
as well as purchases that might have been made anyway, they halved the
initial estimate.' The result of these adjustments was an estimate that
8 million households did reduce their energy consumption by an average
of 5 percent each.

Studies by an EPA contractor and the hardware association raised questions about the link between the program's activities and the reported reductions, as did our analysis of data in the hardware association's study. First, the EPA contractor that analyzed the data on the project's effects said that there was no concrete estimate of the project's impact because, among other reasons, of the difficulty of collecting sales data and a seeming lack of methods for reporting progress in greenhouse gas

'Although program officials said they adjusted the estimated reductions, in part, because some purchases might have been made without the program, we found no analytical basis for either the initial estimate or the adjustment to it.

B-276994

Source Reduction and

Recycling Program

emissions (which would result from reduced energy consumption)
Second, the hardware association's 1995 study of the project's results
found no overall difference in sales between the participating retailers and
a control group of nonparticipants it surveyed, although it cautioned that
the number of retailers responding was too small to be statistically
significant. The study found that about one-third of the participating
retailers who responded said they featured energy- and water-conserving
products from time to time without the project. For this report, we
analyzed certain data presented in the association's study, including sales
data for 31 energy- and water-saving product lines. According to data from
the responding retailers, sales at the nonparticipating retailers increased
more than sales at the participating retailers for 17 of the product lines and
less for the other 14 product lines.

Although the Source Reduction and Recycling Program has two
elements-WasteWise and Unit-Based Pricing-EPA attributed virtually all
of the program's results to WasteWise. According to EPA, 513 companies
were participating in Waste Wise as of March 1997. EPA reported reductions
from Waste Wise of 0.8 to 2.3 MMTCE in fiscal year 1995—the most recent
year for which it calculated greenhouse gas reductions. As with energy
efficiency measures, the trends over the past few years indicate a general
movement toward increased recycling. Recognizing that recycling exists
outside of the program, EPA asks the WasteWise participants to report
separately on recycling associated with the program and general recycling
efforts. EPA officials explained that they compile the participants' reports
and check them for general reasonableness. However, they do not make
any further adjustments.

When we spoke with seven WasteWise participants about their
experience, six of them said they were pleased with the program, generally
because they appreciated the free information provided on recycling and
reducing wastes. While all six also said they were likely or somewhat
likely to have made some of the improvements without the program, two
said that they accelerated their actions because of the program. The
seventh participant said his company was already taking all the steps
recommended by the program.

**Planet Protection Center Program: Presentation and Discussion of Emissions Reductions Results," ICF. Inc. (1996).

"Environmental Merchandising and Advertising/Promotion in the Retail Hardware/Home Improvement Industry. National Retail Hardware Association (Indianapolis, IN: Aug. 1995).

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