A proposed EPA rule would require individual facilities in the U.S. to submit information about their greenhouse gas emissions to the EPA. It would target suppliers of fossil fuels or industrial greenhouse gases, manufacturers of vehicles and engines, and facilities that emit 25,000 metric tons or more per year of GHG emissions.
The proposed measure focuses on facility-level emissions, but does not require identification of the facility’s parent company. In response to EPA’s call for public comments, 57 individual researchers from around the world submitted a joint letter calling for inclusion of a corporate identifier.
Corporate identifiers are important because facility environmental performance varies by the location, size, and financial standing of the parent company. Investors and NGOs are also increasingly interested in corporate-level climate policies and impacts. For example, the Carbon Disclosure Project, Global Reporting Initiative, and budding carbon footprint labeling efforts (See post A Call for Product Carbon Labeling) are dependent upon accurate data to verify corporate sustainability performance.
EPA currently requires corporate parent identifiers in other reporting programs, such as the Risk Management Plan Rule. This small burden on reporters could reduce redundancy and errors that could lead to contradictory conclusions.
The first of the proposed Mandatory Greenhouse Gas Reports are due in 2011. The required public comment period ended on June 9, 2009.
