Reporting of Facility Emissions

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

Reporting of Facility Emissions

Greenhouse gases are released in association with many human activities, by entities large and small. Currently, powerplants report their CO₂ emissions under the Clean Air Act.⁷ A comprehensive program, however, should include a broader array of reporting entities.

One way to strike the balance between establishing a reasonably inclusive program and minimizing the reporting burden, especially on small businesses, would be to require reporting by entities that own at least one facility whose emissions exceed a given threshold. For example, the implementing agency could be directed to set the threshold at the level necessary to bring into the reporting system at least 75 percent of human-induced emissions of GHGs in the United States. (See Figure 1.) Any entity that owns at least one U.S. facility that emits more than the threshold would then report its GHG emissions entity-wide.

Figure 1 Source: U.S. EPA. Inventory of Greenhouse Gas Emissions and Sinks: 1990-2000 (February 2002, draft for public comment). Note: Residential & Commercial emissions are primarily due to fossil fuel combustion for heating. Excludes emissions from U.S. territories.

 

 

 

 

 

 

An alternative approach would be to require any entity with entity-wide emissions above the threshold to report. This approach, however, would require commercial enterprises consisting of several small facilities to conduct analyses of firm-wide emissions just to determine whether they should report. In contrast, requiring reporting by any entity with at least one facility over the threshold — rather than by any entity over the threshold — would keep entities made up of several small facilities out of the system. Reporting and disclosure should also apply to government facilities, many of which are large GHG emitters.

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