FCSG Statement on the Importance of Including Broadcom F-gas Emissions in the City’s Single GHG Inventory

The Fort Collins Sustainability Group (FCSG) insists that Broadcom’s massive greenhouse gas (GHG) emissions be included in the City’s GHG inventory. Those emissions – consisting mainly of fluorinated gases (F-gases) accounted for fully 8% of Fort Collins’ total GHG emissions in 2018. Ignoring those F-gases – or simply mentioning them in a side-bar to the main GHG inventory – is akin to sticking our heads in the sand and pretending that if we don’t count them, those gases won’t really damage the climate.

On March 25th, City staff released a memo (available at https://citydocs.fcgov.com/?cmd=convert&vid=218&docid=3443912&dt=MAIL+PA…) giving an overview of different options for addressing Broadcom’s F-gas emissions. In that memo, staff recommends creating a second GHG inventory that includes F-gases and other “industrial process and product use” (IPPU) emissions side by side with an inventory that follows the same methodology that has been used in the past. However, as staff notes, doing this will create confusion for community members (and others) who will wonder whether our overall emissions are actually going up, staying the same, or going down. This approach also appears not to honestly address the “Guidance Note” dated April 12, 2019 (available at https://www.globalcovenantofmayors.org/wp-content/uploads/2019/04/Data-T…) that accompanies the Global Covenant of Mayors for Climate and Energy Common Reporting Framework, which the City follows. That Guidance Note states that any source of GHG emissions comprising more than 5% of a City’s total emissions should be counted. Broadcom’s emissions exceed this level substantially.

City staff also includes an option in its memo for creating a new GHG inventory that would include known IPPU emissions from large emitters – by which they mean Broadcom. Staff claims that they cannot do this with any certainty going back all the way to 2005, which is the City’s GHG “baseline” against which all subsequent years are compared. We believe that staff significantly overstates this problem. The record of Broadcom’s IPPU emissions (available at https://ghgdata.epa.gov/ghgp/service/facilityDetail/2018?id=1008734&ds=E…) – which the Environmental Protection Agency (EPA) requires it to report as a “Large Facility” responsible for more than 25,000 metric tons of equivalent carbon dioxide (CO2 (e)) emissions annually – goes back to 2011. There is a clear upward trend from 2011 to 2016, which makes “back extrapolation” fairly straightforward. We have done that in the graph attached below, where emissions for 2010 and 2009 are linearly back extrapolated from the 2011 – 2016 data. It appears that before 2009, Broadcom’s IPPU emissions were likely zero or at most less than 1.5% of base year community-wide emissions.

City staff should engage in serious discussions with Broadcom about its manufacturing processes and output prior to 2011 in order to refine this estimate further. However, pre-2011 IPPU emissions from Broadcom – or any other electronics manufacturer – would be highly unlikely to skew the 2005 baseline significantly. This is because Broadcom is the only facility in Fort Collins that emitted more than 25,000 Metric Tons of CO2 (e) in IPPU gases in 2011 and afterward, and because that EPA minimum reporting bar equals just 1% of the City’s total baseline GHG emissions.

The FCSG believes that Broadcom’s IPPU/F-gas emissions should be included in the City’s 2005 GHG Inventory as well as in subsequent years. Doing so would shine a spotlight on this major source of community GHG emissions, thereby encouraging Broadcom to make faster progress in reducing its IPPU emissions. We note that Broadcom’s Environment and Sustainability Policy (available at https://docs.broadcom.com/doc/32081) states that its managers and employees are required to conduct their operations in a manner that supports “prevention of pollution and protection of the environment.” Additionally, Avago Technologies, which acquired Broadcom in 2015, provided representatives to the Citizens’ Advisory Committee that helped develop both the 2008 and the 2015 Fort Collin Climate Action Plans. Broadcom needs to be held accountable for its extraordinarily high GHG emissions. Including those emissions in the City’s GHG inventory would establish that accountability, and would provide Broadcom the opportunity to do a better job of living up to its environmental stewardship claims.

Update: Under “Other Business” at the City Council meeting on May 19, councilmembers directed City staff to include all of Broadcom’s greenhouse emissions in the City’s main greenhouse gas inventory starting in 2019. Staff outlined how it will account for Broadcom’s emissions going forward in a memo dated June 3, which is provided below as the second attachment.


Author: Kevin Cross

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