Vermont Might Change How It Accounts for Climate-Damaging Emissions. Here’s What’s at Stake

To net or not to net. That is (one) question currently under debate in Vermont following Gov. Phil Scott’s introduction of a suite of proposed changes to the state’s climate laws, now under consideration by the state Legislature.

Scott, a Republican, has proposed changing how the state counts greenhouse gas emissions in its official inventory—which the state’s legally binding emissions targets are based on—to include carbon sequestration by forests and farms. His proposal would also replace the state’s declining greenhouse gas emissions targets for 2025, 2030 and 2050 with a single target of achieving and thereafter remaining at “net-zero” emissions by 2035. 

This proposal to switch from gross to net emissions accounting has raised serious questions because it could decelerate Vermont’s transition off fossil fuels and introduce uncertainty into the state’s calculated emissions.

Agency of Natural Resources Secretary Julie Moore, who joined Scott in announcing the proposed changes at a press conference earlier this year, said in an interview that there are two main reasons to change to net accounting. The first is essentially to buy the state more time. 

“The 2030 goal that’s currently in the Global Warming Solutions Act is … not actually practical,” Moore said, pointing to recent studies of two proposed decarbonization policies that found each could impose high up-front costs on Vermonters (but also long-term savings) without getting the state all the way to the target.  Moore said that the governor’s proposed 2035 target is functionally equivalent to the currently enacted target for 2030. 

Environmental advocates say this justification rings hollow and that if the Scott administration had acted more swiftly, the target would have been achievable at lower cost. “In the eight years that Gov. Scott has been in office, we have unfortunately not seen proactive policy proposals and, instead, have gotten vetoes and opposition to solutions proposed by others—which has made it hard to be on a trajectory to meet [the] 2030 target,” said Johanna Miller, energy and climate program director at the Vermont Natural Resources Council.

The second reason Moore gave for changing how the state counts greenhouse gas emissions is to play to the strengths of Vermont’s farms and forests and potentially preserve something that could otherwise be lost.  “Our landscape is disproportionately farms and forests, and there are incredible opportunities in both of those sectors to store and sequester carbon … [while] slow[ing] the rate of loss of our farms and forests,” Moore said.

Yet climate advocates and researchers, while supportive of preserving these resources, have pointed to the uncertainty inherent in measuring the carbon they sequester as reason to be wary of such an approach. 

“A major risk with a net approach is that sequestration numbers that may not be real or accurate would significantly offset emissions from fossil fuel burning that are very real—allowing fossil fuel pollution and costs to stay higher for longer than they would otherwise,” Jared Duval, a member of the State’s Climate Council, testified this week to the House Committee on Energy and Digital Infrastructure.

To understand the impact of the proposal, one must understand how greenhouse gas emissions are currently tracked in Vermont, using what’s known as a “gross” approach. Under that accounting, only certain emissions from agriculture—such as methane from livestock—are included in the official inventory, which also includes emissions from sectors such as transportation, electricity and home-heating. Other, harder to track agricultural emissions and removals—and the entire “carbon flux” associated with forests—are not included in the official inventory, but rather as supplemental information. 

It is difficult to separate the net accounting plan from the rest of Scott’s proposals. Those proposals would also remove the right of citizens to sue if the state is not taking sufficient action to meet, or has not met, one of the required emissions targets. Critics say this removes accountability, while Scott and Moore claim it removes the distraction of litigation. 

Additionally, Scott has proposed changing the composition of the state’s Climate Council, an appointed mix of governmental and non-governmental experts in various aspects of climate science and policy, and reducing its authority to direct the adoption of climate policies via a Climate Action Plan. First released in 2021, the plan is set to be updated this year. 

Moore suggested at the January press conference that such a change could “better align the work of the council with that of state agencies and make it more sustainable for the volunteer members.” Advocates have previously defended the authority of the Climate Council by pointing to multiple prior task forces that made recommendations for climate action to successive Vermont governors, only to see their advice followed partially, and after many delays, if at all.

In comparison, switching to net emissions accounting is a more technical but no less impactful change.

First, the selection of a single “net-zero by 2035” target does represent a slowdown in emissions reductions, compared to the current targets. The scale of the change depends on the accounting methods chosen to project future carbon fluxes, but Moore suggested it essentially moves the 2030 target back by five years. Available data support that equation, albeit with substantial uncertainty.

Presently, state law requires Vermont to emit no more than 5.14 million metric tons of carbon dioxide equivalent (MMT CO2e) annually by 2030 and no more than 1.71 MMT annually by 2050. 

Compared to the official inventory for 2021, these are reductions of 3.14 and 6.57 MMT, respectively. That’s with the current gross emissions accounting framework that does not include the entire carbon flux on forests and farms. 

In the state’s most recent emissions inventory, released last year, the supplemental accounting for greenhouse gas fluxes in the sector that includes land use change and forests found that sector removed, on balance, 6.75 MMT CO2e in 2021, the most recent year for which data is available, leaving net statewide emissions of just 1.53 MMT. This is about half the cut state law currently requires by 2030, let alone 2035, so if that were all the state needed to eliminate, the 2035 goal would be substantially less ambitious than the current 2030 target.

Importantly, however, forests in the state aren’t able to sequester as much carbon as they once did. That’s due mainly to the forests getting older and secondarily to the loss of forestland—almost 6,000 acres are converted to other forms of land use annually. 

According to a just-released inventory from Alexandra Kosiba at the University of Vermont, net carbon dioxide removals by forests were 6.1 MMT CO2e in 2022, and forecasted to fall to 5.4 MMT in 2030 and just under 5 MMT by 2035. 

Using those numbers for the removals brings the quantity of emissions that the state would need to cut in other sectors to meet the net-zero 2035 proposal more in line with the present 2030 target.

Kosiba takes pains to point out that her research is separate from the state’s official inventory. Moore, however, pointed to it in her Inside Climate News interview as research she hopes will help to resolve some important questions on how to account for the carbon flux in forests.

Yet the carbon flux estimates in Kosiba’s forest carbon inventory are subject to enormous uncertainty—the report acknowledges that the actual annual carbon fluxes could be more than 40 percent lower or higher than calculated. This is due both to natural variability (think of forest fires, wind storms or pestilence, events that can drastically impact the flux in any given year) and to the difficulties of measurement.

Both Kosiba and the state’s official inventory relied on a national dataset compiled by the U.S. Forest Service to extrapolate from measured carbon in a series of forest plots, as well as data on harvested wood products, to calculate annual carbon sequestration and emissions associated with the state’s forests. But the use of rough average conversion factors and the scale of extrapolation creates significant uncertainty. 

“I’m pretty confident we’re in the ballpark, but we could be off by more than a million tons in either direction,” Kosiba told me. And, she cautioned, calculations of the carbon flux for the agriculture sector may be even more uncertain.

One area of present uncertainty—and dispute—is how to account for emissions from burning woody biomass for electricity. This proposal could force the state to take an official stance on that issue, which it has yet to do via a formal rulemaking. Vermont has two major biomass plants and several smaller ones, the emissions from which totaled nearly 1 MMT CO2e in 2021, if counted directly. That’s about 12 percent of the recorded gross emissions for the state. 

Following guidance from the Intergovernmental Panel on Climate Change (IPCC), however, such emissions have not been included in the electricity sector and so have not been recorded in the state’s official inventory, but rather have been lumped in with the supplemental tracking for land use and forests. 

Conflicts about how to account for those emissions within that supplement have not been resolved via official action at the state level. Kosiba explained that her forest carbon inventory ostensibly does account for most of these emissions, but only using very broad-brush assumptions. 

“We’ve heard loud and clear from the public concerns over how biomass is currently considered,” Moore said, adding that this is an area where “additional evaluation and consideration is needed as we move forward.” 

Another issue yet to be resolved is how to deal with sales of “carbon offsets” by private landowners in Vermont—a pressing question, given that 80 percent of forests in Vermont are on privately owned land. 

Through these sales, which are not directly regulated by the state, private landowners sell the rights to claim the annual carbon sequestered by their forests as an “offset” to emissions by other actors, chiefly private individuals and companies burning fossil fuels. Many, if not most, of the buyers are outside Vermont. 

If not addressed within a net accounting framework, that would lead to two different actors taking credit for the removals—a no-no from an accounting perspective. 

“Certainly we want to avoid double counting” such removals, Moore said. But Kosiba said the total volume is not presently known, as sales to the so-called “voluntary market” are not publicly tracked, which would make avoiding double counting challenging indeed.

Separate from all of the accounting difficulties is the question of what incentives the state will create by including forest fluxes in its official inventory. Kosiba told me she “can see both sides” of that question. 

“When people see something that we rely on [like forests for carbon sequestration and storage], it is helpful for getting people to care” about that resource, she said. “But I am also, then, cautious, because I don’t want people to only focus on forests for their carbon benefits.” 

She noted that doing so could lead to “maladaptive” forest management, focused only on short-term carbon sequestration benefits and not long-term forest health and resiliency to climate change, or the critical other ecosystem services forests provide.

It could also lead to overestimating how much cover forests can provide to the ongoing burning of fossil fuels in Vermont. 

“I’ve heard this [viewpoint of]: ‘forests will save us from climate change,’” Kosiba said, making clear that is not her view. “Like, they are our ally in this, right? But we really need to make sure that we are reducing anthropogenic emissions first, and that this mitigation effect of forests is of added benefit.”