[Federal Register Volume 75, Number 182 (Tuesday, September 21, 2010)]
[Notices]
[Pages 57506-57514]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2010-23485]
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DEPARTMENT OF LABOR
Bureau of Labor Statistics
Summary of Comments
AGENCY: Bureau of Labor Statistics.
ACTION: Notice of comments received and final definition of green jobs.
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SUMMARY: The Bureau of Labor Statistics (BLS) is responsible for
developing and implementing the collection of new data on green jobs.
The resulting information will be useful for evaluating policy
initiatives and the labor market impact of economic activity related to
protecting the environment and conserving natural resources. BLS
activities also will be useful to State
[[Page 57507]]
labor market information offices in their efforts to meet the need for
information for State policymakers, businesses, and job seekers.
In a Federal Register Notice on March 16, 2010 (75 FR 12571), BLS
solicited comments on the definition BLS will use in measuring green
jobs, the list of industries where green goods or services are
classified, or any other aspect of the information provided in the
notice. The current notice summarizes the comments received and the BLS
response to the comments, and provides the final BLS definition of
green jobs for use in data collection.
Appendices. This notice includes four appendices in the
SUPPLEMENTARY INFORMATION section below. Appendix I summarizes the
comments received on the proposed definition of green jobs and the BLS
response. Appendix II presents the final definition of green jobs BLS
will use for data collection beginning in FY 2011. Appendix III
summarizes comments on identifying industries where green goods and
services are classified and the approach BLS intends to use for data
collection beginning in FY 2011. Appendix IV summarizes comments
received on the BLS plan to measure green jobs and the BLS response.
ADDRESSES: For further information, contact Richard Clayton, Office of
Industry Employment Statistics, Bureau of Labor Statistics, Room 4840,
2 Massachusetts Avenue, NE., Washington, DC 20212 or by e-mail to:
[email protected].
FOR FURTHER INFORMATION CONTACT: Richard Clayton, Office of Industry
Employment Statistics, Bureau of Labor Statistics, telephone number
202-691-5185 (this is not a toll-free number), or by e-mail to:
[email protected].
SUPPLEMENTARY INFORMATION:
I. Summary of Comments on the Green Jobs Definition and BLS Response
In response to the March 16, 2010, Federal Register Notice, BLS
received 156 comments. The largest number of comments was from business
or industry associations (44 comments), followed by State workforce
agencies (22), private employers (20), labor unions (16), individuals
(15), other State or local government (14), academic or research
organizations (9), Federal agencies (8), and nonprofit organizations
(8). BLS reviewed and considered all comments and made certain changes
in the green jobs definition and industry list, as described below.
In the March 16, 2010, Federal Register Notice, BLS requested
comments and recommendations from the public on the definition,
industry list, or any other aspect of the information provided in the
notice. BLS was interested in comments on:
1. Whether the definition of green jobs is clear and
understandable.
2. The comprehensiveness of the definition, including the
composition of the set of economic activities in which green jobs are
involved and the types of green goods and services.
3. Whether the distribution of green goods should be included as
green services.
4. Whether the preparation and sale of organic food by restaurants
and food service industries should be included as green services.
The following summary addresses the comments received on each of
these questions, followed by comments on other topics related to the
definition of green jobs. Comments related to data collection plans are
summarized in Appendix IV.
Whether the definition of green jobs is clear and understandable.
Three comments asked for clarification of the broad definition of green
jobs. One comment noted that, by using both the output and process
approaches, BLS is trying to encompass the broadest definition of green
jobs, although one would want to know the degree of overlap between the
two approaches. BLS agrees this overlap is of interest; the data BLS
will collect will provide an indication but not a direct measure of the
overlap.
One comment questioned whether certain workers would be included,
such as a sustainability manager in a business that is not producing a
green good or service. BLS responds that jobs with the titles listed in
the comment would be captured by either of the two measurement
approaches, depending on where these jobs occur.
One comment noted that the definition should clearly include
development, production, installation, and maintenance activities that
contribute to protecting the environment and conserving natural
resources. BLS has modified the descriptions of the relevant categories
to specifically mention research and development, installation, and
maintenance.
The comprehensiveness of the definition. Ten comments addressed the
broad definition of green jobs. Three comments agreed with the broad
definition, with one of these comments noting that this is a new area
for data collection and the dimensions are somewhat unknown until data
collection occurs. Three comments encouraged BLS to narrow the
definition, with one of these comments citing policy needs for credible
and concrete data, and one of these comments expressing the fear that
the definition of green becomes so broad as to make it not useful.
Two comments recommended wording changes to reference ``growing the
economic engine'' or ``promoting sustainability.'' BLS has not adopted
these changes, as they suggest policy positions or advocacy roles
inappropriate for a statistical agency.
Whether the distribution of green goods should be included as green
services. Thirty-one comments addressed whether distribution of green
goods should be included in the BLS definition of green goods and
services. The proposed BLS definition includes services that specialize
in the distribution of green goods, including certain detailed
industries in the North American Industry Classification System (NAICS)
sectors of Transportation and Warehousing, Wholesale Trade, Retail
Trade, and Real Estate and Rental and Leasing. Including these
industries would result in the identification of green jobs in, for
example, trucking, grocery stores, and motor vehicle dealers.
Thirteen comments recommended excluding distribution activities.
Most of these comments based their recommendation on lack of skill
differences for workers involved in distributing green goods versus
those distributing other goods. In response, BLS notes that its green
jobs definition is not based on skill differences, but instead on the
environmental impact of the good or service produced or the production
process used. Several comments expressed concerns about the feasibility
and cost of data collection in the distribution sectors.
Ten comments recommended including distribution only on the basis
of whether the distribution process is green (e.g., use of energy-
efficiency vehicles). BLS responds that distribution activities
conducted using environmentally friendly production processes will be
addressed in the process approach to data collection.
Eight comments recommended including distribution. One commenter
noted that their State green jobs survey had identified jobs in the
transportation industry and related occupations. BLS notes that it is
unclear in this State survey whether these jobs were reported because
of the nature of the good being transported or the nature of the
production process.
Five comments recommended including distribution but narrowing the
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scope of what is included. These comments would narrow the scope
variously, such as limited to ``the extent a distributor deals
predominantly or exclusively in green goods;'' only if ``the primary
function is green related;'' only if ``the overall net impact of those
jobs is positive or neutral at best;'' and if ``the distribution
services are a subdivision of a company that is selling energy
efficient or organic produce, then the distribution costs for that
percentage of the business should be included.''
Three comments recommended BLS investigate local and regional food
networks or include locally produced foods as green. BLS responds that
food producers who distribute locally and businesses that purchase
locally produced food have adopted an environmentally friendly process
that will be covered in the process survey.
BLS has determined to exclude distribution of green goods from its
definition of green goods and services. Transporting or selling a green
good has no apparent benefit to the environment compared to
transporting or selling any other good.
Whether the preparation and sale of organic food by restaurants and
food service industries should be included as green services. Twenty-
two comments responded to this question. The proposed BLS definition
includes services classified in Accommodation and Food Services
industries such as restaurants, caterers, and cafeterias.
Ten comments recommended excluding this activity from the
definition of green goods and services. Generally, these comments noted
that the environmental benefit of organic food is in the production
stage, not in the preparation and sale. Several comments expressed
concerns that including this activity would lead to overcounting the
number of green jobs.
One comment that recommended excluding this activity noted an
inconsistency in the proposed definition in the treatment of organic
food products versus goods containing recycled inputs. BLS agrees with
this comment and has addressed this inconsistency in its final
definition.
Eight comments recommended including this activity. One comment
said the reason was to encourage the growth of organic farming; BLS
responds that it does not have an advocacy position on organic farming.
One comment noted that the purchase and end use is as important as
production of organic products because without the buyers and markets,
no organic farming could exist. One comment noted environmental impacts
in this category, i.e., using fresh versus packaged food, reduces
packaging waste and using composting practices diverts waste from the
landfill. BLS notes that these practices are not inherent to organic
foods.
Three comments recommended including this activity only on the
basis of whether the process is green; another comment said that if the
activity is counted as a green service, then it should not be counted
in the process approach.
BLS has determined to exclude preparation and sale of organic food
from its definition of green goods and services. Preparing or selling
organic food has no apparent benefit to the environment compared to
preparing or selling other food.
Need for a standardized definition of green jobs. Thirteen comments
noted the need for a standardized national definition of green jobs,
and some comments indicated an expectation that the BLS definition
would be adopted for other than statistical purposes. BLS responds that
it is developing the definition of green jobs only for use in
collecting and analyzing data. Other uses of the definition have played
no role in its development.
Job quality and worker characteristics. Eleven comments expressed
concerns about the statement in the Federal Register Notice that the
definition does not consider job aspects unrelated to the work itself,
such as wages, union membership, benefits, or career ladders. Some of
these comments urged BLS to use criteria such as worker health and
safety, wages and benefits, and career pathways. BLS responds that
using such criteria would require BLS to determine, for example, what
level of worker safety is high enough for the job to be included as a
green job. Making such determinations would be inappropriate for a
statistical agency, which must refrain from policy advocacy to maintain
its credibility among data users. However, data users may make use of
information on worker safety, wages, and other topics to select jobs
from the BLS data that meet their own criteria regarding these topics.
Two comments cited the need for demographic characteristics of
workers in green jobs. BLS does not plan to collect demographic data in
its surveys. However, users may be able to supplement the BLS green
jobs data with demographic data from other sources.
Categories of green economic activity: General comments. Three
comments addressed the categories of green economic activity in
general. One comment recommended including ``operation and
maintenance'' in each instance where development and implementation are
listed. BLS agrees that green goods maintenance services should be
included and has changed the descriptions for the relevant categories.
One comment noted that the categories are highly integrated and not
necessarily independent. BLS agrees with this comment. The categories
do overlap and are not intended to be mutually exclusive. The purpose
of the categories is to establish the scope of green jobs. BLS may
decide to tabulate data from the green goods and services survey
according to these categories, recognizing that such a tabulation would
sum to greater than the total number of green jobs identified, and
requires clear explanation to data users. Alternatively, BLS could
assign each industry where green goods or services are produced to only
one category, so the categories sum to the total number of green jobs
identified.
One comment supported the use of ``reduction'' throughout the
definition, but noted that this does not address the goal of
environmental sustainability and climate stability. The comment stated
that ``while the seven economic activities are comprehensive * * * they
do not capture the underpinnings of business and industry that create
these economic activities and their associated environmental outcomes.
It would help to articulate the management policies and operational
systems that lead to these outcomes.'' BLS responds that it is unclear
how the commenter would change the definition or data collection.
BLS has determined to consolidate the seven categories into five
categories for green goods and services and four categories for
environmentally friendly production processes. Additionally, BLS has
determined to modify the term ``categories of green economic activity''
to ``categories of green goods and services'' and ``categories of green
technologies and practices used within establishments.'' See Appendix
II of this notice.
Category 1, Renewable energy. Five comments addressed category 1.
One comment recommended that BLS merge this category with categories 2
(energy efficiency) and 3 (greenhouse gas reduction), creating a single
``clean energy'' category, with the proposed category addressing only
energy systems. BLS has determined to merge certain categories, as
described in Appendix II of this notice. These decisions do not affect
category 1, however.
One comment recommended that BLS modify the description to show the
sources of renewable energy consistent with the statutory definition.
BLS has
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modified the description to reflect the sources listed in Section
203(b) of the Energy Policy Act of 2005, with the exception of the
qualification of hydropower. The statutory definition includes as
renewable only ``new hydroelectric generation capacity achieved from
increased efficiency or additions of new capacity at an existing
hydroelectric project.'' BLS finds this qualification too complex to be
used in employment surveys and therefore includes all hydroelectric
generation as a green good. In response to this comment, BLS has
changed the description to add landfill gas and municipal solid waste
as renewable sources, and remove hydrogen fuel cells.
One comment recommended that the description include installation
and maintenance. BLS agrees that these activities are included and has
modified the description accordingly. One comment asked whether trading
of certificates and offsets is included. BLS responds that these
activities are included. They could be placed in categories for
renewable energy, pollution reduction and cleanup, or greenhouse gas
reduction, depending on what is being traded.
One comment recommended that BLS expand the description to include
``construction workers who build and install technologies that harness
or collect renewable energy.'' BLS responds that these workers are
included in the proposed definition, and should be identified in the
data collection.
Category 2, Energy efficiency. Four comments addressed category 2.
Two comments recommended that BLS clarify where energy storage and
distribution are categorized, including the electric power grid and
battery technologies, and whether BLS intends to distinguish between
the storage and distribution of energy from renewable sources versus
energy from other sources.
BLS has determined to categorize improving the efficiency of the
electric power grid, including Smart Grid technologies, in category 2.
BLS has also determined that electric power distribution services are
not included as a green service, similar to its decision on
distribution of other green goods and services as discussed above.
One comment recommended that BLS break out transportation
efficiency and other sources of efficiency. BLS responds that it does
not see a need for this breakout.
One comment asked that BLS clarify whether the category means to
include ``energy efficiency products'' not ``energy-efficient
production of any product.'' BLS responds that both ``energy efficiency
products'' and ``energy-efficient production of any product'' are
included, with the latter identified as an environmentally friendly
production process. The revised presentation of the categories makes
this clearer.
Category 3, Greenhouse gas reduction. Five comments addressed
category 3. One comment stated agreement with the inclusion of research
and development activities in this category. One comment recommended
moving nuclear energy to category 1, renewable energy. BLS responds
that nuclear power is not renewable energy, as the fuel source is not
renewable.
Two comments supported including nuclear energy in this category,
while one comment opposed including nuclear energy as a source of green
jobs. One comment supporting inclusion of nuclear energy recommended
keeping it as a separate category for data tabulation, as many
stakeholders will likely reject nuclear energy as a source of green
jobs. BLS responds that it intends to tabulate data from the green jobs
surveys by NAICS industry, which should result in presentation of data
specifically for NAICS 221113 Nuclear electric power generation as well
as other NAICS categories, providing transparency and allowing users to
exclude sectors for their own purposes. BLS continues to include
nuclear energy in the final definition on the basis of lower greenhouse
gas emissions relative to other major sources of electric power.
One comment recommended eliminating ``reduction of GHG emissions in
electricity from fossil fuels'' from this category, noting that ``every
fossil fueled power plant * * * is or will soon be trying to make
incremental improvements to its emissions intensity, but that activity
will not `green' the fossil fuel industry and nor will it qualify the
associated power plants as `green energy.' '' Another comment supported
including this activity, noting that ``energy production includes jobs
that design and apply cleaner technologies to coal such as
gasification, pyrolysis, and carbon capture and sequestration (CCS).
CCS is still under development but our definition includes efforts that
seek to reduce adverse impacts of coal in the near future while the
country works to develop clean, renewable energy sources.'' BLS
responds that activities in the fossil fuel industry to make
incremental improvements to its emissions intensity represent
establishments adopting environmentally friendly production processes
and should be measured in the BLS green process survey. BLS also notes
that the proposed definition includes research and development of CCS
as a green activity, and the planned surveys should identify this
activity, depending on where it is being performed.
Category 4, Pollution reduction and cleanup. Five comments
addressed category 4. These comments generally supported the category
and recommended including the words ``prevention'' and/or
``elimination'' in the description. BLS agrees with this recommendation
and has revised the description accordingly.
One comment recommended merging category 4 and category 5
(recycling and waste reduction), noting that there is some overlap in
the categories. BLS has determined to merge certain categories, as
described in Appendix II of this notice. This decision combines
categories 3, 4 and 5 into one category.
Category 5, Recycling and waste reduction. Forty-four comments
addressed category 5. These comments generally recommended adding
certain activities to the description, specifically reuse (29
comments), remanufacturing (23), composting (22), reduction or
elimination (7), deconstruction (4), repair (2), and demanufacturing
(1). BLS has revised the description to include reuse, remanufacturing,
composting, and avoiding creation of waste materials. ``Reuse''
includes reuse of building materials.
One comment recommended creation of new NAICS codes related to
composting. BLS responds that revising the NAICS is outside the scope
of the BLS green jobs initiative.
One comment recommended that recycled goods be included only on
evidence that they typically had previously entered the waste stream;
another comment recommended the category recognize producer
responsibility for recycling product at end of life. BLS responds that,
while these suggestions may have merit, they are more complex than BLS
data collection processes could reasonably identify.
One comment recommended rewording the description to include
greater detail about the nature of recycling. BLS responds that it does
not believe this additional detail is needed.
One comment recommended rewording to include stormwater management.
BLS agrees with this recommendation and has included stormwater
management in the natural resources conservation category.
Two comments opposed including solid waste landfills, incineration,
waste-to-energy, or landfill-to-energy
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activities as green activities. BLS responds that it has added
municipal solid waste and landfill gas as sources of renewable energy,
consistent with the statutory definition of renewable energy sources.
Category 6, Agriculture and natural resources conservation.
Eighteen comments addressed category 6. Fourteen of the comments
concerned the inclusion of additional NAICS industries on the industry
list in the area of forestry and wood products, specifically 113110
Timber Tract Operations, and manufacturing industries related to wood
and paper products. BLS has added timber tract operations to the list
of industries producing green goods and services, based on timber
tracts producing timber meeting sustainable forestry standards.
BLS continues to include on the industry list industries producing
certain wood products meeting standards, such as LEED-eligible
construction materials. One comment criticized the use of the LEED
standard to identify green wood products and recommended alternative
standards. BLS is examining the recommended standards.
One comment recommended this category include activities that take
place in urban areas. BLS agrees that activities in urban areas are
included; the key is environmental impact of the activity, not where it
occurs.
Two comments asked for clarification of the term ``natural
resources conservation.'' One comment recommended that the category
include land management and water conservation. BLS agrees that these
activities are included; they are specifically mentioned in the
description for this category.
Category 7, Education, compliance, public awareness, and training.
Eight comments addressed category 7. Two comments supported including
this category. One comment called for deleting the category, stating
that ``all industries perform these as a public service and academia
trains in them as its mission. Compliance is a regulatory and process
review activity, not an economic one--no good or service is produced.''
BLS responds that education and compliance are services industries
recognized in the NAICS.
One comment recommended adding ``internally within the
organization'' in addition to the point of raising public awareness.
One comment noted that this category does not denote any green
function, but agrees that the jobs meant to be included in the category
are green. This comment proposed counting jobs in this category under
each of the preceding categories, depending on the type of training
provided. BLS has determined to retain a separate category for
education and compliance goods and services, as some of these outputs
span across two or more of the preceding categories. BLS has determined
to drop this category from the categories of environmentally friendly
production processes, and to include training of an establishment's
staff or contractors in application of environmentally friendly
technologies and practices in the remaining four categories.
One comment recommended the category be more open to allow
respondents to include themselves, e.g., add `other' or `similar
services.' BLS responds that, if these categories are presented on data
collection forms for either the green goods and services survey or the
process survey, an ``other'' response may be provided.
One comment stated that it was unclear what types of jobs would
count. BLS responds that the approach is under development and will be
specified on the data collection instruments.
One comment recommended that health and safety education and
compliance related to green jobs may deserve special notice within this
category. BLS does not see how health and safety education and
compliance related to environmental problems has a beneficial impact on
the environment.
Comments recommending additional categories. Seven comments
recommended adding new categories. Two comments recommended adding a
category ``Environmental health'' to cover work to protect public
health and worker health from the adverse effects of environmental
problems. For the reason given in the paragraph above, BLS rejected
this suggestion.
Two comments recommended adding a category ``Sustainable design,
construction, and operations.'' BLS responds that these activities are
related to energy efficient building design, construction, and
operation, and are covered in the category 2, Energy efficiency.
One comment recommended adding a category ``Emission inventory
management and trading and compliance.'' With the clarification that
emission offset trading is included as a green activity (see discussion
of category 1, above), BLS has addressed this comment.
One comment recommended adding a category for the transportation
sector, mentioning equipment manufacturing, public transit operation
and maintenance, public transit infrastructure, and all road
construction involved in repair ``as long as those construction
projects are linked to greenhouse gas emissions reductions and/or oil
savings goals.'' BLS responds that the definition of green goods and
services includes the equipment manufacture and public transit topics.
Some road construction activities are also included; it does not seem
feasible to use the suggested criterion in BLS data collection.
One comment recommended adding a category ``Water efficiency''
similar to ``Energy efficiency,'' noting that the proposed categories
mainly focus on energy, and that water is not included except for the
mention of water conservation in category 6. The comment recommended
including activities such as water conservation, drinking water
protection, and stormwater management. BLS responds that the
recommendation appears to be an elaboration of ``water conservation''
which is already included in the natural resources conservation
category, and wastewater management, which is included in the pollution
reduction category. Stormwater management has been added to the
description for the natural resources conservation category.
Types of green goods and services, general comments. Ten comments
generally addressed the definition of green goods and services, with a
focus on the extent to which the supply chain or production chain is
included in the BLS definition.
Most comments recommended including all of the ``supply chain'' or
all stages from inputs to final sale. One comment, however, noted that
``going too far down the chain reduces the `greenness' of the good
because it could be shipped, stored, or sold with many other nongreen
goods.''
Two comments pointed out inconsistencies in the treatment of
organic food products versus recycled inputs. The proposed BLS
definition includes organic food products from specialized inputs
through specialized distribution and sale, while recycled products are
included only up to the stage where the recycled inputs are introduced.
BLS notes that including the entire production chain is difficult
for products other than organic foods, which carry a specific
certification label, and would greatly expand the list of industries in
which green goods are classified. These comments also relate to the
question about whether to include distribution of green goods as a
green service, discussed above.
BLS has determined to drop the use of the four types of green goods
and services from its final definition. Many
[[Page 57511]]
comments indicated that these types were not clear or helpful to data
users.
Direct green goods and services. One comment addressed treatment of
Recyclable Material Merchant Wholesalers in the NAICS. BLS responds
that revising the NAICS is outside the scope of the BLS green jobs
initiative. However, this NAICS industry is included in the industry
list as producing a green service.
Indirect green goods and services. Two comments addressed indirect
green goods and services. One comment said the qualifier ``favorable *
* * relative to other goods'' is vague. BLS responds that it intends,
where possible, to use existing Federal or industry standards to make
this qualifier more specific. BLS also notes that, without the
``relative'' qualifier, it would have little or no basis to make a
distinction between green and nongreen goods or services that are not
``direct'' and would exclude a large number of products and services
that are generally considered green.
One comment said the distinction between direct green products and
indirect green products seems unclear: For example, why is weatherizing
a building directly green, but producing renewable energy is indirectly
green? BLS responds to this example by noting that weatherization is
conducted specifically for an environmental purpose, the definition of
a direct good or service. Producing renewable energy is conducted to
produce electricity, but has an environmental benefit, and thus fits
the definition of an indirect green good or service.
Specialized inputs. One comment recommended that specialized inputs
be rolled into indirect green goods and services, noting that examples
such as USDA approved fertilizers, wind turbine blades, and mass
transit rail cars fit the definition of indirect, i.e., they are
``produced for another purpose, but when produced, consumed, or
scrapped have a favorable impact on protecting the environment or
conserving natural resources.''
Standards. Twenty-six comments addressed the BLS plan to use
existing Federal or industry standards to identify indirect green goods
and services. Most of these comments suggested specific standards for
BLS to consider or commented on the standards listed in the Federal
Register Notice as examples. BLS finds these comments very helpful.
II. Definition of Green Jobs BLS Will Use for Data Collection
In response to comments received on the proposed definition, as
well as additional considerations, BLS has revised the definition of
green jobs. The final definition will be used in data collection
beginning in FY 2011, and is presented below, following a discussion of
the nature of the changes.
Categories of green jobs. BLS has changed the term ``categories of
green economic activity'' to ``categories of green goods and services''
and ``categories of green technologies and practices used within
establishments.''
BLS has revised the name of category 1 to ``Energy from renewable
sources.''
BLS has revised the description of category 2, ``Energy
efficiency,'' to include improving the efficiency of energy storage and
distribution, including Smart Grid technologies.
BLS has combined categories 3 (greenhouse gas reduction), 4
(pollution reduction and cleanup), and 5 (recycling and waste
reduction) into one category, now labeled ``category 3, Pollution
reduction and removal, greenhouse gas reduction, and recycling and
reuse.'' Combining these categories reduces to some extent the overlap
among categories. The description for this category has been edited to
include mention of eliminating emissions of pollutants and to include
reuse, remanufacturing, composting, and avoiding creation of waste
materials.
BLS has revised the title of category 4 (formerly category 6) to
``Natural resources conservation.''
BLS has edited the descriptions of categories 1 through 4 (formerly
1 through 6) to include the terms research and development,
installation, and maintenance.
BLS has revised the title of category 5 (formerly category 7) to
``Environmental compliance, education and training, and public
awareness.'' This category now appears only in relation to green goods
and services.
Types of green goods and services. BLS has dropped the use of the
four types of green goods and services (direct, indirect, specialized
inputs, and distribution). BLS has excluded distribution of green goods
from its definition of green services.
Final BLS definition of green jobs. BLS has developed this
definition of green jobs for use in data collection in two planned
surveys.
Green jobs are either:
A. Jobs in businesses that produce goods or provide services that
benefit the environment or conserve natural resources.
B. Jobs in which workers' duties involve making their
establishment's production processes more environmentally friendly or
use fewer natural resources.
The BLS approach to identifying each type of green job for
measurement purposes is described in more detail below. The planned BLS
surveys may identify and count some jobs in both surveys.
A. Jobs in businesses that produce goods and provide services that
benefit the environment or conserve natural resources. These goods and
services are sold to customers, and include research and development,
installation, and maintenance services. This definition will be used in
the BLS survey of establishments in industries that produce green goods
and services. Green goods and services fall into one or more of five
groups:
1. Energy from renewable sources. Electricity, heat, or fuel
generated from renewable sources. These energy sources include wind,
biomass, geothermal, solar, ocean, hydropower, landfill gas, and
municipal solid waste.
2. Energy efficiency. Products and services that improve energy
efficiency. Included in this group are energy-efficient equipment,
appliances, buildings, and vehicles, as well as products and services
that improve the energy efficiency of buildings and the efficiency of
energy storage and distribution, such as Smart Grid technologies.
3. Pollution reduction and removal, greenhouse gas reduction, and
recycling and reuse. These are products and services that:
Reduce or eliminate the creation or release of pollutants
or toxic compounds, or remove pollutants or hazardous waste from the
environment.
Reduce greenhouse gas emissions through methods other than
renewable energy generation and energy efficiency, such as electricity
generated from nuclear sources.
Reduce or eliminate the creation of waste materials;
collect, reuse, remanufacture, recycle, or compost waste materials or
wastewater.
4. Natural resources conservation. Products and services that
conserve natural resources. Included in this group are products and
services related to organic agriculture and sustainable forestry; land
management; soil, water, or wildlife conservation; and stormwater
management.
5. Environmental compliance, education and training, and public
awareness. These are products and services that:
Enforce environmental regulations.
Provide education and training related to green
technologies and practices.
Increase public awareness of environmental issues.
[[Page 57512]]
B. Jobs in which workers' duties involve making their
establishment's production processes more environmentally friendly or
use fewer natural resources. These workers research, develop, maintain,
or use technologies and practices to lessen the environmental impact of
their establishment, or train the establishment's workers or
contractors in these technologies and practices. This definition will
be used in the BLS survey of establishments across all industries to
identify jobs related to green technologies and practices used within
the establishment. These technologies and practices fall into one or
more of four groups:
1. Energy from renewable sources. Generating electricity, heat, or
fuel from renewable sources primarily for use within the establishment.
These energy sources include wind, biomass, geothermal, solar, ocean,
hydropower, landfill gas, and municipal solid waste.
2. Energy efficiency. Using technologies and practices to improve
energy efficiency within the establishment. Included in this group is
cogeneration (combined heat and power).
3. Pollution reduction and removal, greenhouse gas reduction, and
recycling and reuse. Using technologies and practices within the
establishment to:
Reduce or eliminate the creation or release of pollutants
or toxic compounds, or remove pollutants or hazardous waste from the
environment.
Reduce greenhouse gas emissions through methods other than
renewable energy generation and energy efficiency.
Reduce or eliminate the creation of waste materials;
collect, reuse, remanufacture, recycle, or compost waste materials or
wastewater.
4. Natural resources conservation. Using technologies and practices
within the establishment to conserve natural resources. Included in
this group are technologies and practices related to organic
agriculture and sustainable forestry; land management; soil, water, or
wildlife conservation; and stormwater management.
III. Summary of Comments on Identifying Industries Where Green Goods
and Services Are Classified and the Approach BLS Will Use for Data
Collection
Forty-seven comments recommended adding a total of 371 detailed
NAICS industries to the list of industries where green goods and
services are classified. Six comments recommended dropping 18 detailed
NAICS industries from the list. Numerous comments addressed certain
details on the industry list.
BLS notes that many of the comments were based on whether
establishments in the industry may use environmentally friendly
production processes, rather than whether the product or service meets
the BLS definition of a green product or service. The purpose of the
industry list is only to identify industries where green goods and
services are classified.
A large number of the industries were recommended for addition to
the list based on the use of recycled inputs, such as numerous
fabricated metal products industries that may use recycled metals. BLS
notes that recycled products are included only up to the stage where
the environmental impact occurs, and do not include products fabricated
from materials containing recycled content. Therefore BLS has not added
these industries to the list.
Some comments requested changing the type of green good or service
from indirect to direct, apparently based on a belief that direct green
goods or services are preferred over other types of green goods or
services. BLS notes that the direct and indirect types were used as
criteria for determining what goods or services to include as green,
and indicate no hierarchy or preference. These types are not included
in the final definition.
BLS has revised the industry list to be consistent with the final
definition of green jobs and in light of its review of comments
recommending inclusion or exclusion of specific industries. The revised
list is posted at http://www.bls.gov/green, along with a separate list
showing the industries added or dropped from the list published with
the March 16, 2010, Federal Register Notice. The following table
presents the industry sector distribution of business establishments
that potentially produce green goods and services. The establishment
counts represent the number of establishments eligible for sample
selection for the green goods and services survey. The approximately
2.2 million eligible establishments compare to a total of 9.0 million
establishments on the BLS business list in 2009. The number of
establishments that potentially produce green goods and services could
change over time as industries currently offering green goods and
services grow or decline, or as new or different industries begin to
produce green goods and services.
Number and Percent Distribution of Establishments in Industries Where
Green Goods and Services Are Classified, by Industry Sector, 2009
------------------------------------------------------------------------
Number of Percent
Industry sector establishments distribution
------------------------------------------------------------------------
Construction........................ 820,700 38.1
Professional and business services.. 779,100 36.2
Other services (Repair and 183,300 8.5
maintenance services, Professional
organizations).....................
Natural resources and mining........ 88,700 4.1
Information......................... 77,000 3.6
Manufacturing....................... 77,700 3.6
Trade, transportation, and utilities 49,300 2.3
Public administration............... 42,100 2.0
Education and health services....... 26,400 1.2
All other sectors................... 10,400 0.5
-----------------------------------
Total........................... 2,154,700 100.0
------------------------------------------------------------------------
In general, the BLS approach is to designate as green those goods
and services that directly benefit the environment or preserve natural
resources. The BLS approach does not (automatically) designate as green
the goods and services produced by industries that supply inputs to or
distribute the outputs from green producing industries. Instead, BLS
first evaluates those supplier and distributor industry goods and
services for whether
[[Page 57513]]
they directly benefit the environment or preserve natural resources.
Green goods and services may be sold to intermediate demand or to final
demand.
IV. Summary of Comments on Plans To Measure Green Jobs and BLS Response
BLS received comments on its approach to measuring green jobs and
specific measurement plans. These comments are summarized in this
Appendix, and the BLS response is indicated.
General measurement approach. One comment expressed unqualified
support for the output and process approaches.
Two comments disagreed with the BLS approach. One of these comments
recommended using the O\*\NET categories and focusing on occupations in
the output approach. BLS responds that the O\*\NET program in the
Employment and Training Administration is developing information on
green jobs and an effort by BLS to collect similar data would be
duplicative. Further, data users will be able to use O\*\NET
information in conjunction with the BLS green jobs data, since both
sources use the Standard Occupational Classification.
One comment disagreeing with the BLS approach recommended that
``BLS make it clear that this is a `green firm survey' and not a `green
jobs survey' '' and that ``the BLS is more concerned with measuring
jobs created by the demand for green products and not necessarily green
jobs per se.'' BLS responds that it is referring to the survey to be
used in the output approach as the ``green goods and services survey.''
Three comments pointed out that the BLS approach will miss green
goods and services produced by firms classified in NAICS industries
excluded from the list. Establishments are classified into NAICS
industries based on the goods or services that account for the majority
of their revenue. Establishments not classified into an industry on the
BLS list will not be included in the green goods and services survey;
if a minority of their revenue is from a green good or service, these
goods or services and the jobs related to them will not be identified.
BLS is aware of this limitation and notes that how large this
limitation may be is unknown.
Use of share of revenue to apportion share of jobs. In the green
goods and services survey, for establishments that produce both green
and nongreen goods or services, BLS proposed to capture the share of
establishment revenue received from the sale of green goods and
services. (An alternative to revenue will be used for nonmarket
sectors.) BLS plans to use the revenue share as a proxy for the share
of the establishment's employment associated with the production of
green goods and services.
Fifteen comments agreed with use of revenue, and seven comments
disagreed. Both types of comments cited collectability and respondent
burden as reasons for their agreement or disagreement. Some comments
disagreeing with the approach questioned whether the result would
overestimate the number of green jobs, and said the results would be
difficult to interpret. BLS responds that its field research to date
indicates that respondents are generally able to provide share of
revenue information and this information is more readily available than
share of employment. BLS also notes that this result is similar to the
experience of Statistics Canada in its environmental surveys.
Eleven comments pointed out limitations of the revenue share
approach, suggested other measures (employment, hours, task
proportions, degree of shift to green practices or sustainability),
recommended attempting to collect employment as well as revenue, and/or
recommended field testing. BLS responds that it is conducting field
testing of both share of revenue and share of employment, and that the
collection of hours, task proportions, or degree of shift to green
practices or sustainability would be more difficult to collect than
shares of revenue or employment.
One comment recommended that, regarding electric power distribution
jobs associated with ``clean energy,'' BLS count jobs associated with
transmission and distribution as proportional to the quantity of clean
energy flowing on the grid. Consistent with its decision to exclude
distribution of green goods from the definition of green services, BLS
has determined that the operation of the electric power grid is not
included as a green good or service. However, goods and services or
processes that improve the efficiency of energy storage and
distribution, such as Smart Grid technologies, are included in category
2, energy efficiency. Construction of the power transmission facilities
to connect new renewable energy sources to the grid is included in
category 1, energy from renewable sources.
Coverage and sampling frame, green goods and services survey. Three
comments addressed the coverage and sampling frame for the green goods
and services survey. One comment expressed concern about exclusion of
the self-employed. BLS responds that this limitation is imposed by
nature of the BLS business list that will be used as the sampling
frame.
One comment recommended that, for the construction industry, BLS
should rely on a sampling frame of projects, not establishments. BLS
responds that such a frame is not available and would result in data
based on a different concept than for other industries.
One comment suggested that BLS work with the National Agricultural
Statistics Service (NASS) if BLS has a need to expand coverage of farms
beyond the BLS business list, where coverage of agriculture production
is limited. BLS has determined that the scope of its green jobs data
collection will be wage and salary employment within the scope of the
Quarterly Census of Employment and Wages (QCEW) program, except private
households. All NAICS industries in this scope will be surveyed in the
process survey; only those NAICS industries identified as producing
green goods or services will be surveyed in the goods and services
survey. While QCEW coverage of NAICS Sector 11 Agriculture, Forestry,
Fishing and Hunting is not as complete as in most other industries, BLS
believes it is comprehensive enough for purposes of green jobs data
collection.
Measuring occupational employment and wages. Six comments addressed
the collection of occupational data from establishments in the green
goods and services survey. Certain of these comments indicate that the
Federal Register Notice did not provide sufficient description of the
plans concerning occupational data collection. BLS responds that it
intends to collect an Occupational Employment Statistics (OES) schedule
from establishments sampled for the green goods and services survey.
These responses will allow estimation of occupational staffing
patterns, employment, and wages for those establishments reporting
green goods or services and for those not reporting such goods or
services. BLS has not yet developed the specific estimation methods to
account for establishments that report producing both green and
nongreen goods or services.
One comment recommended that survey respondents be asked directly
to identify the job titles of positions that meet the BLS definition of
``green.'' BLS responds that, in the process survey, respondents may be
asked to provide job titles, which would be coded using the SOC. For
the occupations of jobs related to production of green goods and
services, however, the existing OES survey procedures will be used,
which do not ask respondents for job titles.
[[Page 57514]]
One comment stated that determining green job occupations based on
OES assumes that green jobs are distributed throughout the workforce in
the same proportion by occupation as all jobs. The commenter stated
that results of their State survey indicated that green jobs seem to be
widely disbursed, but are more concentrated in construction and
extraction, production, and farming and fishing occupations. BLS
responds that occupational employment will be estimated using OES data
for specific establishments, according to whether or not they produce
green goods or services. This is different from using OES estimates for
overall employment.
Two comments concerned the BLS plan to count jobs in all
occupations in the establishment in the green goods and services
survey, with one comment agreeing and one comment saying there is ``no
need to count support jobs, such as accountants or administrative
staff, because their job duties are not affected directly by the green
product or service and thus they do not require additional training.''
BLS notes that its green jobs definition is not based on skill
differences, but instead on the environmental impact of the good or
service produced or the production process used. However, data users
can select the occupations they wish to consider for training offerings
from those BLS identifies as occurring in establishments producing
green goods and services. The O\*\NET green occupations taxonomy should
be useful in this type of analysis.
Data by public ownership. One comment encouraged BLS to generate
data that identify the level of public sector green employment in the
NAICS-defined industries and the characteristics of the public sector
green jobs. BLS responds that it intends to provide data from the green
goods and services survey by public versus private ownership.
Process approach to measuring green jobs. BLS plans to develop a
special employer survey to test the feasibility of collecting data on
jobs associated with use of environmentally friendly production
processes. Environmentally friendly production processes and practices
are those that reduce the environmental or natural resources impact
resulting from production of any good or service. These production
processes include (1) production of green goods and services for use
within the establishment, and (2) use of technologies and practices
that have a positive environmental or natural resources conservation
impact.
Sixteen comments addressed the process approach. Five comments
supported using this approach and one comment recommended against.
Three of these comments emphasized that all industries should be
included in the process survey. BLS responds that, as stated in the
March 16, 2010, notice, the scope of the process survey will be all
industries.
Six comments indicated the need for more clarity in the process
approach. BLS responds that the approach is under development and will
be described in a future notice.
Two comments recommended using product life-cycle criteria for
identifying green goods, with one of these comments suggesting that ``a
`green good' and a good produced with `green processes' will become
increasingly indistinguishable in the marketplace among the leading
experts and stakeholders in the sustainable products field.'' BLS
responds that applying life-cycle criteria or identifying
``sustainable'' products is not feasible in its data collection.
Signed at Washington, DC, this 26th day of August 2010.
Kimberley Hill,
Chief, Division of Management Systems, Bureau of Labor Statistics.
[FR Doc. 2010-23485 Filed 9-20-10; 8:45 am]
BILLING CODE 4510-24-P