Information Required on Facility Emissions

Greenhouse Gas Reporting and Disclosure: Key Elements of a Prospective U.S. Program

Information Required on Facility Emissions

Measurement and reporting of emissions should be done according to generally accepted reporting standards and established by rule of the agency (or agencies) charged with administering such a program. One existing tool that could serve as the basis for reporting emissions from a particular facility is the Greenhouse Gas Protocol Initiative Corporate Accounting and Reporting Standard, which was developed through an international multi-stakeholder process.⁸ Ultimately, a balance must be struck between developing reasonably complete information and minimizing the burden on the reporting entities. One way to strike this balance would be to require covered entities to report the GHG emissions released: (1) directly from all but their smallest U.S. facilities, (2) from their vehicle fleets, and (3) as indirect emissions⁹ estimated to be associated with imported electricity, heat, or steam (e.g., by using standard factors under the reporting protocol). Each of these three would be reported as a separate item of information to prevent double counting when the data are aggregated — for example, of the indirect emissions from electricity use by a manufacturer and the direct emissions of its power company. These factors represent the main emissions sources under the control of most reporting entities.

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