17 February 2004 FE# 6299

Electronic submission to: 1605bgeneralguidelines.comments@hq.doe.gov

Re: GM's comments covering the Department of Energy (DOE) 1605b Workshop
held on January 12^th^ 2004, (including additional detail per GM's
January 9^th^ 2004 submittal).

GM is pleased to offer the following comments to clearly define our
positions regarding the proposed revisions to the General Guidelines as
follow-on to our January 9^th^ 2004 submittal and participation in the
January 12^th^ 2004 workshop.

As stated in GM's January 9^th^ 2004 submittal, GM believes the
fundamental premise for reporting should be: "entities have
responsibility for reporting, that which is under the entity's direct
ownership and/or management/operational control." Certain companies may
choose to report on issues beyond this scope, for example to share best
practices or other voluntary initiatives, but there should be no
obligation in this regard. Simply put, "Whoever uses the energy, owns
the ensuing GHG emissions and reductions."

The following statements attempt to clarify, with more detail, the six
issue areas that we defined in GM's January 9^th^ 2004 submittal as very
important in establishing a strong program for GHG reporting for America
and to ensure that current participation is maintained and more entities
are encouraged to begin participating in order to grow total engagement
in reporting to the 1605(b).

1\. Treatment of Reported pre-2002 Reductions: GM reaffirms that if a
company was proactive in taking voluntary actions to reduce and
sequester GHG emissions and reporting emissions, removals, and
reductions [to the existing 1605(b) registry from a base-year of
1990]{.underline}, and it recasts its previously reports into a format
that qualifies under the updated 1605(b) Guidelines, then it should not
be penalized by having its reported and verifiable CO2 reductions
ineligible for [registration]{.underline} into the 1605(b) Registry. The
1605(b) should provide a GHG Reporting System open and available to
anyone who can satisfy the data requirements of the Guidelines. GM
agrees with the view taken by the DOE in the proposal that the purpose
of 1605(b) is to report GHG emissions, reductions, and removals, not to
create, on its own, a system of transferable "credits" for early action.

2\. Reporting of Absolute Emissions and Absolute Reductions vs.
Intensity Indicators: GM supports the reporting of absolute emissions.
GM also supports the reporting of absolute emission reductions rather
than the use of intensity indicators to convey an entity's performance
within the national registry.

The following example, reiterated from GM's January 9^th^ 2004
submittal, is specific to the automotive industry and represents that
the use of CO2 intensity indicators can be used by an entity,
internally, to monitor self-performance rather than performance within
or across a sector.

> For 2002, GM's U. S. Operations CO2 intensity indicator was 2.35
> million metric tons of CO2 per vehicle produced, while its global
> intensity indicator was 1.73 million metric tons CO2 per vehicle
> produced. The variance is predominantly dependent and defined by the
> upstream generation of electricity that is being purchased by the
> vehicle manufacturer. A typical vehicle manufacturer's annual energy
> usage is approximately 60% indirect (purchased electricity). The US
> upstream generation is predominantly coal-based, whereas globally it
> is a mix of nuclear and hydro (i.e. Canada), with coal and natural
> gas.

In the reporting of absolute emissions and absolute reductions, shifts
in production should be allowed to shift the absolute totals since the
CO2 tonnage reductions are real and measurable. And, the entity has no
'measurable' control over the demand of the customer.

Accordingly, GM believes that the use of Intensity Indicators to
indicate emissions reductions should only be submitted by the entity if
the entity ALSO submits absolute emissions and absolute reduction
totals.

3\. Definition of Entity, De Minimis and Large Emitter Status: GM
defines its entity GHG footprint as that of ownership and/or
management/operational control. GM believes that this provides a
reasonable approach to establishing corporate boundaries that are
appropriate for reporting GHG emissions, reductions and offsets and is
effective in avoiding the issue of double counting of emissions and/or
reductions. Therefore, an entity should be allowed, but NOT REQUIRED, to
report on any and all aspects of their owned and/or
management/operationally controlled Corporate Boundary [regardless of
emitter status]{.underline}.

> Definition of de minimis: GM believes that the definition of an entity
> and the absence of de minimis threshold emissions should be clearly
> stated up front in the filing of the 1605(b) annual report. Note: The
> level of CO2 emitted, reduced or removed is typically calculated
> rather than read from a meter. Therefore, GM does not support the use
> of a 3% or below de minimis threshold as outlined in the proposed
> 1605(b) Guidelines since in many cases a 3% threshold is well within
> the 'level of uncertainty' of a CO2 calculation. GM instead defines
> its entity by using a 5% or above materiality threshold for CO2
> emissions and does not report those GHG emissions that are below the
> 5% de minimis threshold. For GM, as well as the auto industry, this
> means that, of the six Kyoto gases, its CO2 emissions, and CO2
> equivalent emissions from the use of halogenated substances, are the
> only emissions above the 5% materiality threshold.

GM believes that the 1605(b) reporting and registering must remain
flexible and enable, not require, those entities that report and
register their emissions, reductions, and offsets for U.S. Operations to
[also]{.underline} submit non-U.S. emissions, reductions, and offsets.
Entities should also be allowed to submit reports per business unit
and/or operating structure but should designate which countries the
business unit/operating structure operates in.

GM also believes that the DOE should NOT develop a "more prescriptive"
approach to the definition of entities, such that they correspond to
those used for "Federal Tax Purposes," as a requirement for
participation in reporting to the 1605(b).

4\. CEO Certification Should Not be Required: GM believes that entities
should be allowed to submit annual GHG emission and reduction reports to
the DOE 1605(b) with internal sign-off certification by a registered
Professional Engineer (P.E.), a Ph.D. Engineer, or an officer of the
company. CEO certification should not be required or recommended.
However, a possible alternative would be for a CEO to identify who
within their organization is responsible for reporting and signing-off
on annual reports to the 1605(b).

Note: Federal law prohibits any person or entity from knowingly and
willfully making any false or fraudulent statement of any material fact
to any department or agency of the U.S. Government (18 U.S.C. 1001).
This prohibition, with its substantial penalties, should deter anyone
from making false or fraudulent submissions to the 1605(b).

5\. Entity and Project Reporting vs. Registration in a 2-tiered system
with Issues of 3^rd^ party Verification Requirements: GM supports the
proposed 2-tiered system for reporting vs. registration of CO2
emissions, reductions, and removals across an entities footprint that
can include internal as well as external projects. However, for
reporting and registration, GM believes that 3^rd^ party
certification/verification should not be required at the time of
reporting or registration. 3^rd^ party certification/verification should
occur at the discretion of the entity, [as it may be necessary to
facilitate a trade.]{.underline}

GM also reserves comment on reporting and registration of project-level
reductions until the technical Guidelines are released for public
comment.

6\. All U.S. Voluntary Energy and GHG Reduction Programs should Report
to a Single U.S. Reporting System: GM believes that the DOE 1605(b)
should be the single, national GHG Reporting System used to show
progress across all voluntary energy and GHG reduction programs
(including those programs operated by states and NGOs) within the U.S.,
and should allow for the reporting and registration of non-U.S. GHG
emissions and reductions.

GM would also support the inclusion of language within the DOE 1605(b)
to indicate that ALL (International; such as ISO 14064, Federal, State,
Local) voluntary energy GHG reporting and reduction programs should
report their progress to the 1605(b) in order to: (1) reduce the effects
of proliferation of various other GHG reporting Guidelines and
Standards, and (2) ensure a democratic process across all interested
stakeholders in the development of GHG Reporting Guidelines and
Standards.

GM plans to submit comments following the release of the Technical
Guidelines.

![](media/image1.png)Respectfully Submitted,

Kristin B. Zimmerman, Ph.D.

General Motors Public Policy Center

Environment & Energy Policy

313-665-9164

[kristin.b.zimmerman@gm.com](../kristin.b.zimmerman@gm.com)

cc: E.A. Lowery

T.A. Wakefield

[Margot.Anderson@hq.doe.gov](../Margot.Anderson@hq.doe.gov)
[larisa.dobriansky@hq.doe.gov](mailto:Lerisa.dobrianski@hq.doe.gov)