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Is Criticism of EPA GHG Reporting Rule Justified?

andyhultgrenmug2In a recent article, a representative of consulting firm CRA International criticized the proposed Environmental Protection Agency Greenhouse Gas Reporting Rule for including both upstream and downstream reporting of emissions, saying it was “costly” and “duplicitous” to take such an approach.

It is correct that it is more costly to report downstream greenhouse gas emissions (such as furnace emissions, automobile emissions, or smokestack emissions) than it is to report upstream emissions (such as the carbon content of natural gas extracted from a natural gas well).

For example, consider that there are far fewer points of natural gas extraction (e.g. natural gas wells) than there are points of natural gas combustion (e.g. furnaces and boilers throughout all of America’s homes and businesses).  So, reporting emissions “upstream” means much fewer entities need calculate their GHG emissions, which means a much lower reporting cost burden on America’s private sector.

However, the EPA estimates that under its proposed rule, out of the millions of homes and businesses throughout America, only 13,000 entities would be required to report their GHG emissions.  Through its judicious use of the downstream reporting requirement for only the largest of emitters and upstream reporting for all other emissions, the EPA estimates it will capture 90 percent of total US greenhouse gas emissions.

Now, about the EPA being “duplicitous” in its requirements for both upstream and downstream emissions reporting: the EPA gives good justification for their approach within the text of the proposed rule. For example, see the following quotation from page 94 of the proposed rule.

“There is inherent double-reporting of emissions in a program that includes both upstream and downstream sources.  For example, coal mines would report CO2 emissions that would be produced from combustion of the coal supplied into the economy, and the receiving power plants are already reporting CO2 emissions to EPA from burning the coal to generate electricity.  This double-reporting is nevertheless consistent with the appropriations language, and provides valuable information to EPA and stakeholders in the development of climate change policy and programs.

“Policies such as low-carbon fuel standards can only be applied upstream, whereas end-use emission standards can only be applied downstream.  Data from upstream and downstream sources would be necessary to formulate and assess the impacts of such potential policies.”

The EPA is not only defining a reporting rule, but they are also defining a data set upon which national policy decisions will be based.

This means data has to be available to support a range of policy options, including both upstream and downstream regulatory measures; thus the proposed rule to include mandatory reporting of upstream emissions as well as a limited selection of downstream emissions.

Andy Hultgren is a project manager and the greenhouse gas reporting technical lead for Environmental Performance Group.

Andy Hultgren
Andy Hultgren is a Sustainability Project Manager with the SWCA Environmental Performance Group, and co-founder of Say it Green, which sells organic, fair trade apparel.
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3 thoughts on “Is Criticism of EPA GHG Reporting Rule Justified?

  1. The air, water and land beyond a defined property boundary of a private commercial facility or activity are essentially public resources. If public resources are being used to disperse emissions from a private source and the emissions are of lawful public concern; the public should have a right to know the name/location of the source, the emission types, and the emission quantities during particular timeframes. In the case of regulated private and public utilities, the operations of both the utilities and their suppliers, are of importance to the public and the relevant regulatory authorities.

    Smokescreen claims about reporting (eg costly, duplicitous or proprietary/trade secrecy)by owners and operators of commercial emission sources will become a costly blunder for industry when the public catches on to the intentional deceptions of the typical few bad actors.

    Efficient commercial activity is linked to publicly perceived honesty.

  2. Our homes are on Delrose Drive East In Lakeland Florida, have been used as a pollution barrier for years.
    The County changed the zoning and let 2 big corporation expand with out ever discussing or notifying us. I am about the tenth person to come down with Cancer, seems breast cancer is the dominant one. The residents that don’t get cancer are not so lucky in my book, they become mentally and
    emotionally unable to live normal lives. We have begged out community leaders for 15 years
    for them to either test the water, air or soil and at least put up an autistic monitor up so they can
    see how illegal the decibels are. We are still being ignored. I now have a personal interest as
    I can’t beat these cancers anymore and have become a huge advocate on facebook to get the word
    out. If there is anyway you know that can help me please feel free to write or call me.
    Rebecca Lacey 2541 E. Delrose Drive
    Lakeland Fl 33805
    Phone # 863-666-2699
    You can Google earth Saddle Creek Corporation and you will see our little starter homes
    protecting all others residents as they keep expanding and we keep dieing off. I have
    come across a site called Environmental Justice that talks about our civil rights and we may
    just have some rights after all. The lawyers are all waiting for me to organize and do a class action law suite
    I just want justice done. I am tired and going broke from so many surgeries but I do consider
    myself one of the lucky ones, as I am still off sound mind. I do not have the money to pay
    these lawyers and nor does anyone else in this neighborhood. The two companies have laughed
    at our cries and told us due to our low income level we will not be able to prove anything as we would have to hire a geo engineer or lawyers and they cost. Don’t let CSX and Saddle Creek literally bully us to death.
    Please help me prove them wrong.
    Thank you.

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