Verification and Enforcement

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

Verification and Enforcement

Any mandatory program is only as effective as efforts to verify its results and enforce compliance. Toward this end, GHG emissions reports should be submitted annually on designated reporting forms by the covered entities. The forms should be self-reported and signed by an authorized officer of the firm to certify that emissions reported are accurate and complete. As with TRI reporting, entities should face civil penalties if they either fail to report or intentionally misrepresent their emissions. Several current environmental reporting programs allow, for example, fines of up to $25,000 per day of violation for failure to report or false reporting.

The agency administering the program could develop additional verification requirements — including requiring other data to supplement or corroborate the initial filing, and allowing for site inspections. Companies could choose to engage third-party verifiers to review their data, but verification by such entities would not be required for reporting their direct and indirect emissions. Third-party verifiers should receive government certification to ensure the integrity of their results. The implementing agency should establish minimum criteria to ensure that the certifications are of the highest possible quality and the methodologies are consistent.

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