# COMMENTS OF THE GENERAL ELECTRIC COMPANY

## ON THE 

**US DEPARTMENT OF ENERGY**

**REVISED FORM EIA-1605 AND INSTRUCTIONS**

**70 *Federal Register* 37798**

# June 30, 2005

The General Electric Company (GE) submits the following comments on the
US Department of Energy (DOE) Revised Form EIA-1605 and Instructions. GE
is a large and diversified manufacturing and services company with many
facilities that emit greenhouse gases (GHGs). Our facilities manufacture
a wide array of consumer and industrial products, from aircraft engines,
lighting products, and efficient electric generation, distribution and
control systems, to appliances, locomotives, medical equipment, and
high-grade engineering thermoplastics. We also operate service
businesses in many industrial sectors and the NBC television network and
Universal Studios. In addition, we have a significant financial services
business.

GE has provided information to the public on its inventories since its
first inventory was done in 2002. GE is considering the voluntary
reporting of GHGs through the DOE 1605b program as one potential media
for keeping the public informed of its progress toward meeting its GHG
reduction goals. Therefore, GE has a considerable stake in the
development of an appropriate 1605b program that allows it to measure
and report its GHG reductions in a fair and transparent manner and to
communicate its progress in a cost effective manner.

GE is aware that DOE has spent considerable effort in revising the
program. Much of the guidance information presented is very useful and
is greatly appreciated. The references in the Instructions to sections
in the Technical Guidelines are particularly helpful.

GE appreciates this opportunity to review and comment on the revised
reporting forms and instructions. The Reporting Forms, along with the
General and Technical Guidelines will have a big impact on the success
of the DOE 1605b Voluntary Reporting of Greenhouse Gases Program.

Please direct any questions concerning these comments to:

##  Bob Schenker

Manager -- Air Pollution Control

Corporate Environmental Programs

General Electric Company

3135 Easton Turnpike, W1B

Fairfield, CT 06431

Phone: (203) 373-2691

Fax: (203) 373-2650

e-mail: <Bob.Schenker@corporate.ge.com>

## 

## [BACKGROUND]{.smallcaps}

GE has just completed its third consecutive annual global GHG inventory
covering emissions during the 2004 calendar year. GE is planning to
conduct a GHG inventory each year and will continue to report results on
the GE.com web site.\
\
GE\'s GHG inventory methodology was modeled after the widely recognized
World Resources Institute (WRI)/World Business Council for Sustainable
Development (WBCSD) protocol (the "Protocol"). GE's inventory accounts
for both direct and indirect emissions. Direct emissions are those
originating directly from GE facilities because of on-site fuel
combustion and/or manufacturing processes. Indirect emissions are those
that originate at non-GE locations, but that are attributable to GE
operations through GE\'s purchase of electricity, steam and/or hot water
from off-site utilities and other energy suppliers. For direct
emissions, GE uses primarily published emission factors from the
Protocol. For indirect emissions, GE uses published emission factors
from the North American Electric Reliability Council (for the U.S.) and
the International Energy Agency (for other countries).\
\
GE\'s GHG inventory database includes information on all six of the
recognized GHG\'s emitted from the following types of GE facilities:

-   Manufacturing Facilities

-   Service/Distribution Facilities with \>50 Employees

-   GE\'s Corporate and business unit headquarters offices

A total of 557 GE facilities were inventoried worldwide for 2004.

In addition, GE has estimated emissions from its vehicle fleets,
corporate air transport operations, and more than 5,000 small sites
worldwide.

GE includes controlled affiliates in the inventory in accordance with
the Protocol, whereby a company accounts for 100% of the GHG emissions
produced by operations over which it has control. Control is defined in
the Protocol as the ability to direct the operating policies of an
operation.

GE conducts its GHG inventory through a proprietary web-based tool
called GE PowerSuite^®^. Each GE site performs its GHG inventory by
entering information into PowerSuite on fuel and utility use and process
emissions. PowerSuite then uses preprogrammed emission factors to
calculate GHG emissions. Extensive data quality reviews are conducted on
the data entered into PowerSuite to assure the accuracy of the GE GHG
inventory.

Information on our GHG Inventory and our other climate change activities
may be found at the following website:

<http://www.ge.com/en/commitment/ehs/climate/immelt.htm>

### COMMENTS

GE first presents a number of general comments followed by comments in
response to specific requests from DOE followed by detailed comments on
the Revised Forms and Instructions.

[General Comments]{.underline}

1.  GE Comments on the Interim Final General Guidelines and the Draft
    Technical Guidelines are incorporated into these comments by
    reference and are transmitted herewith. GE provided significant
    comments on the Interim Final General Guidelines and the Draft
    Technical Guidelines because many changes were needed in the 1605b
    program to make it workable. These changes also need to be reflected
    in the Revised Form EIA-1605 and Instructions. Therefore, GE is
    resubmitting its comments to assure that the team preparing the
    Revised Form EIA-1605 reviews them.

2.  The Revised Form EIA -- 1605 may not be useful for those entities
    that wish to only report emission reductions. The General Guidelines
    states under "What Can You Report?" that, "The form also provides
    the opportunity for reporting annual reductions of greenhouse gas
    emissions and increases in carbon fixation realized in 1991 and
    subsequent years." Yet the form only allows the reporting of a
    "start year" baseline that is a one to four year period ending in
    2002 and reporting for subsequent years. As a result, a reporting
    entity will not be able to report reductions realized in 1991 and
    subsequent years. The Revised Form EIA -- 1605 attempts to address
    both the reporting and registration of emission reductions. However,
    it has been structured to only allow the reporting or registration
    of reductions after 2002 (2005 if the reporting entity is not able
    to certify that the inventories before 2005 have been prepared in
    accordance with the final General and Technical Guidelines).
    "Reporting" and "Registration" are two different processes that DOE
    is trying to address with the same form. In so doing, DOE fails to
    take into consideration the reporting that has been done by
    reporting entities before the 2005 inventory (earlier if a reporting
    entity can make the required certification). DOE should revise the
    forms to allow the reporting of emission reductions that are based
    on baselines that are established before the official "start year"
    and that have been prepared in accordance with the existing 1605b
    program that is currently in place. Alternatively, DOE should
    consider a complete separation to allow the reporting and
    registration of emission reductions on different forms.

3.  A reporting entity cannot certify that reported direct emissions,
    direct emission reductions, or sequestration are not included in the
    1605b report of any other reporting entity. GE reports 100% of all
    GHG emissions and all GHG emission reductions from activities over
    which it has control, as recommended in the Protocol. This means
    that GE will be reporting 100% of GHG emissions and GHG emission
    reductions from activities that have multiple owners where GE has
    operational control. In most cases, the reporting of emissions and
    reductions was not anticipated when joint venture or other multiple
    ownership agreements were established. Therefore, GE does not have a
    legal basis for controlling the GHG reporting activities of its
    ownership partners and cannot certify that its partners have not
    also reported emission and reductions in a 1605b report. Significant
    effort and cost would be required to renegotiate agreements to
    address this issue.

4.  The certification statement in the revised Form EIA -- 1605 and
    Instructions is inconsistent with the certification statement in the
    Interim Final General Guidelines. The Interim Final General
    Guidelines requires the following certification in Section
    300.10 (c) (1):

> "The reporting entity took reasonable steps to ensure that direct
> emissions, emission reductions, and/or sequestration reported are
> neither double counted nor reported by any other entity."
>
> The Revised Form EIA - 1605 includes the following certification
> language in Section 2.2 of Schedule VII:
>
> "None of the direct emissions, direct emission reductions, or
> sequestration reported in this 1605b report are included in the 1605b
> report of any other entity for the same calendar year."
>
> Not only are these two certification statements inconsistent, they are
> both inappropriate. A reporting entity cannot "ensure" that any
> actions are or are not conducted by its ownership partners, as argued
> in our written comments on the Interim Final Guidelines. Therefore,
> there are no "reasonable steps" that a reporting entity can take to
> ensure that emission reductions are not also reported by another
> entity. In addition, a reporting entity may not make the certification
> statement included in the revised FORM EIA -1605 as discussed in the
> comment above.
>
> Reporting entities can certify that their emissions and reductions are
> accurate. In addition, reporting entities can identify large
> subsidiaries that have multiple ownership. Reporting entities cannot
> certify anything about what ownership partners do or don't do.

5.  The Revised Form and Instructions should be consistent with the
    final revised General and Technical Guidelines. The revised Form
    EIA - 1605 will be used to collect data to implement the 1605b
    program described by the General and Technical Guidelines.
    Therefore, the form should be consistent with the final General and
    Technical Guidelines and it should implement the 1605b program as
    described in the final General and Technical Guidelines. GE has
    already identified one major inconsistency above concerning the
    certification statement. DOE should carefully compare the revised
    Form --1605 to the final General and Technical Guidelines to assure
    that the final Form EIA-1605 properly implements the 1605b program.

6.  The Revised Form and Instructions should not be finalized until the
    General and Technical Guidelines are finalized. As stated above, the
    revised Form EIA -- 1605 should be consistent with the final General
    and Technical Guidelines. GE and many other stakeholders submitted
    numerous detailed comments on the Interim Final General Guidelines
    and Draft Technical Guidelines. DOE has already stated that it will
    delay the issuance of the final General and Technical guidelines
    until late in the year to give it time to fully review and act on
    the comments submitted. DOE should not finalize the FORM EIA -- 1605
    until the General and Technical Guidelines are finalized to assure
    that the form is consistent with the guidance provided.

[Comments in Response to the Specific Requests from DOE]{.underline}

1.  The proposed collection of information goes beyond what is necessary
    for the proper performance of the agency and practical utility. In
    comments on the Interim Final General Guidelines and Draft Technical
    Guidelines, GE argued that that there are two potential purposes for
    the emission reduction registration provisions: 1) to allow
    reporting entities to report reductions to demonstrate progress
    toward publicly stated GHG reduction goals; and 2) to allow
    reporting entities to register reductions for future trades of these
    reductions to other companies. The emission reduction registration
    provisions discussed in the Interim Final General Guidelines and
    addressed in the Revised Form EIA -- 1605 do not achieve either
    goal. Reporting entities that want to simply report progress toward
    meeting a goal may find that participation in the emission reduction
    registration program is too difficult and expensive for a voluntary
    program due to the certification, emission rating system,
    limitations on allowable reductions and other provisions. Reporting
    entities that wish to register emission reductions for future trades
    will find that the emission reduction registration program is not
    sufficiently robust and, given that no broad trading scheme exists
    in the U.S., the program is too speculative and may not, in fact,
    work in connection with a scheme that may later develop.

2.  The reporting deadline of July 1, 2006 is too early in the year. GE
    has had difficulty meeting a July 1 GHG Inventory submittal date
    under the existing 1605b program due to the size and complexity of
    its GHG Inventory collection efforts and due to the significant time
    required to complete data quality reviews. The effort required to
    submit a GHG Inventory under the revised 1605b program will be
    increased significantly, making it that much harder to meet a July 1
    submittal deadline. For 2006, significant factors that may impact
    the submittal date are the date on which the final General and
    Technical Guidelines are released and the extent of changes that GE
    must make to its GHG Inventory and collection efforts to meet the
    final General and Technical Guidelines. GE will start making
    preparations to collect its 2005 GHG Inventory in November and
    December 2005. Primary data collection will extend from January to
    March 2006. If the preparation for the 2005 GHG Inventory is delayed
    because of a delay in the release of the final General and Technical
    Guidelines, then a corresponding delay will occur in the GHG
    Inventory submittal date. If the final General and Technical
    Guidelines get delayed beyond the first of the year, then GE may be
    required to move forward without the final General and Technical
    Guidelines and its 2005 GHG Inventory may not qualify for
    certification under the revised 1605b program.

3.  A submittal deadline of July 1 cannot be met if a reporting entity
    conducts an independent verification. At the present time, GE does
    not conduct an independent verification of its GHG Inventory.
    However, if it did, it could not even start the independent
    verification until all data quality reviews were completed in late
    June or early July. Therefore, GE's GHG Inventory submittal would
    likely be delayed until September if it conducted an independent
    verification.

4.  The reporting burden estimate of 40 hours per response for GHG
    Inventory data collection, calculations, validation, analysis,
    reporting and certification is very low for GE. GE estimates that it
    spent approximately 6,200 person-hours (Approximately 3.4
    person-years) to prepare its 2004 GHG Inventory as shown in the
    table below. More than 500 in-house personnel participated in the
    preparation of the 2004 GHG Inventory.

  ------------------ ----------------------------------- ----------------
  Staff              Item                                Person-Hours

                                                         

  Corporate          Planning                            40

                     Database support                    60

                     Preparation of guidance materials   40

                     Training business and site          40
                     personnel                           

                     Site screening, tracking and        60
                     analysis                            

                     Response to questions during data   80
                     collection                          

                     Tracking data entry                 20

                     Identification, communication,      300
                     responding to questions, tracking   
                     and documentation of data quality   
                     issues (150 issues x 2 hr/issue)    

                     Collection of data and calculations 80
                     for small sites and mobile sources  

                     Data analysis and internal          40
                     reporting                           

                     Management Oversight                40

                     Subtotal                            800

                                                         

  Business           Site screening                      20

  (15 Business       Preparation and training            60
  Reps.)                                                 

                     Assistance to sites                 200

                     Resolution of data quality issues   120

                     Subtotal                            400

                                                         

  Sites              Training of site personnel (150     220
                     people trained at 1.5 hr/person)    

                     Data collection and database entry  4,456
                     (557 sites x 8 hr/site)             

                     Resolution of data quality issues   300
                     and revision of the database (150   
                     issues x 2 hr/issue)                

                     Subtotal                            \~5,000

                                                         

  Total                                                  6,200
  ------------------ ----------------------------------- ----------------

> Note that the reported time for site data collection and database
> entry varies widely from 2 hours per site to 70 hours per site
> depending on the size and complexity of the site, number of sources
> and utility accounts, the need to calculate non-utility process
> emissions, the need to previously collect the same data for other
> environmental reporting and the experience of the personnel involved.
> An average of 8 hours per site has been assumed based on reported hour
> estimates from a limited number of sites.
>
> In addition, GE spent approximately 40 person hours to restate data
> into the proper format, to prepare explanatory text, to enter data
> into the existing reporting form, to obtain the certification and to
> submit the data to DOE for 2004.
>
> As stated below, under the comments concerning the entity statement in
> Schedule I of revised Form EIA -- 1605, GE does not currently
> centrally collect much of the data required for the entity statement.
> In addition, GE is a very large corporation with a complex
> decentralized structure that is constantly undergoing change.
> Information would have to be collected from numerous different
> operating units and subsidiaries around the world. It is estimated
> that the central Corporate staff and personnel in the various
> operating units and subsidiaries would have to spend more than one
> hundred hours to collect the information required for Schedule I
> depending on the level of detailed required for Schedule I. In
> addition, more than a hundred hours would be required to prepare and
> document the data and complete the forms for the remaining schedules.
> A requirement to prepare Schedules II -- IV for each of 69 country
> subentities would greatly increase the time required to prepare the
> forms. These hours would be spent over and above the 6,200 hours
> discussed above for preparation of the GHG Inventory.

5.  Costs will result from changing GHG Inventory processes to conform
    to the revised General and Technical Guidelines and the Revised
    Forms. GE's current GHG Inventory conforms to the Protocol. It will
    have to make changes in its processes and web-based data collection
    database to conform to the final General and Technical Guidelines.
    In house start-up costs will be incurred in making these changes.

6.  Costs will be incurred each year for operation and maintenance of
    the GHG Inventory. A very major effort is required to administer the
    GHG Inventory each year. For example, significant effort is needed
    to prepare for the GHG Inventory each year including communication
    and training for business and site personnel, maintenance of the
    web-based data collection database, tracking of data collection
    efforts, performance of data quality reviews, preparation of
    reports, and documentation of data. This recurring effort is in
    excess of the actual data collection efforts.

7.  The proposed Automated EIA-1605 Reporting System should be
    sufficiently flexible to allow for large and complex submittals from
    very large and diverse reporting entities such as GE. When DOE
    prepares an electronic reporting system, it should provide
    sufficient electronic field space in Schedule I for the submittal of
    GE's very large Entity statement. For example numerous pages will be
    required by GE to respond to each issue under entity statement
    changes. Additional pages will be needed for GE to respond to the
    organizational boundaries and geographic scope of activities. Note
    that GE has already had difficulty with the existing forms and has
    had to submit its site list separately because it did not fit into
    the available fields in the form.

8.  The US EPA Climate Leaders program collects similar information. GE
    will have to provide similar information on GHG emissions and
    reductions to the US Environmental Protection Agency as a partner in
    the Climate Leaders Program. GHG Inventory data required by EPA for
    this program is based on the Protocol and therefore differs to some
    extent from the data collection anticipated by DOE under the 1605b
    program since DOE has chosen to deviate from the precedent set by
    the Protocol.

[Detailed Comments]{.underline}

General Instructions

1.  The text under "What is the Start Year?" is inconsistent with the
    text under "What can you Report?" Under "What Can You Report?" the
    General Instructions state that,

> "The form also provides the opportunity for reporting annual
> reductions of greenhouse gas emissions and increases in carbon
> fixation realized in 1991 and subsequent years."
>
> However, under "What is the Start Year?" the General Instructions
> state that,
>
> "The Start Year is \[the\] year upon which the initial entity
> statement is based and must be the year immediately preceding the
> first year for which the entity tends to register or report
> reductions. It is the last year of the Base Period and can be no
> earlier than 2002."
>
> These statements are inconsistent. How can one report reductions in
> 1991 and subsequent years if the baseline period must be based on a
> start year (one to four year base period ending no earlier than 2002)?

2.  Sulfur Hexafluoride (SF6) was omitted from the list of greenhouse
    gases that should be reported under "What Gases Can You Report?"

3.  The requirement to report emissions and emission reductions
    separately for each individual country under "Can You Report Foreign
    Activities" is not needed for the proper performance of the agency.
    It would be a significant burden to require GE to submit separate
    subentity forms for each of the 69 countries in which we emit GHGs
    (Submittal of a Schedule II, III, IV and V for each of 69 countries
    would be a total of 276 Schedules). It should be sufficient to
    separately report US and total foreign emission and emission
    reductions. This requirement presents a significant disincentive
    against the reporting of non-US emissions and reductions.

4.  Under "Do You Have Questions or Comments?" the text refers to an
    "above mailing address." No mailing address is provided.

Schedule I

1.  \[Form Item 3.a\] Under "Report Characteristics", the instructions
    state that, "You must submit a Start Year report." GE's baseline
    year for measuring progress toward meeting our GHG reduction goals
    will not qualify as a "start year" report. GE has designated 2004 as
    its baseline year for measuring progress toward meeting its GHG
    reduction goals. However, the final General and Technical Guidelines
    were not available when GE completed its 2004 GHG Inventory.
    Therefore, GE's 2004 GHG Inventory does not conform to the final
    General and Technical Guidelines and GE cannot certify that its 2004
    GHG Inventory meets the requirements of the final General and
    Technical Guidelines. Furthermore, GE will not be able to revise its
    2004 GHG Inventory to conform to the final General and Technical
    Guidelines because of the significant time and effort that would be
    involved. Therefore, GE's first report submitted in 2006 for the
    2005 GHG Inventory under the final General and Technical Guidelines
    will be a "Reporting Year" report. In fact, GE will not be able to
    submit a "Start Year" report. It is likely that numerous other
    reporting entities that have set GHG emission reduction goals will
    be in the same position as GE. The requirement that a "Start Year"
    must be certified to the final General and Technical Guidelines will
    serve as a significant disincentive against the reporting of
    reductions.

2.  \[Form Item 4\] GE understands the need for providing information on
    significant changes to the previous entity statement. However, GE is
    concerned over the level of detailed information that is requested
    in this section of the form. GE expects to make significant changes
    to its entity statement every year. For example in 2004:

    -   GE added 80 sites to its detailed inventory because of
        acquisitions, disaggregations, opening of new sites and
        availability of new data for existing sites;

    -   GE removed 69 sites because of divestitures, site closures and
        aggregations;

    -   GE transferred economic activity to and from specific operations
        covered by a previous report due to a major business
        restructuring;

    -   GE acquired and divested numerous land holdings;

    -   GE changed output at many of its 557 major facilities because of
        an improving economy;

    -   GE changed numerous contractual arrangements;

    -   GE changed equipment and processes at some plants;

    -   GE changed the outsourcing and insourcing of some activities;
        and

    -   GE changed some business arrangements (i.e., joint ventures,
        subsidiaries, control of entities, etc.)

> Significant effort and time would be required to compile all of this
> information. GE centrally tracks the additional of new plants, the
> removal of old plants, and changes in control at facilities because
> this information may have a major impact on GE's GHG Inventory. Much
> of the remaining information requested in this section is not
> centrally tracked by GE and will be difficult to collect in a cost
> effective manner.

3.  \[Form Item 5\] The concept of primary and secondary economic
    activities is not meaningful for a complex and diverse company like
    GE. GE did report one SIC code (SIC Code 35, \"Industrial and
    Commercial Equipment and Components\") in its 2004 1605b submittal
    as requested by the existing reporting form. However, GE listed a
    total of 25 SIC Codes in the Additional Information. No one or two
    SIC Codes stand out as being primary or secondary because GE is so
    large and diverse. It should be sufficient for reporting entities to
    list the various NAICS codes for the industries that they
    participate in.

4.  \[Form Item 6\] For corporations, a check box needs to be added for
    "Parent Corporation" under "Ownership Status".

5.  \[Form 8.b and c\] GE is a very large and diverse corporation with a
    very complex structure. There are numerous subsidiaries of all
    kinds, many that are wholly owned and many that are partially owned
    under complex ownership agreements. The form asks for "All Large
    Wholly Owned Subsidiaries" and "Any Large Partially Owned, Joint
    Venture and Leased or Operated Emission Sources." There is no
    definition of the word "Large." Subsidiaries that are considered to
    be large by other corporations may be small in GE's viewpoint. GE is
    concerned that it may have to provide lists of hundreds of wholly
    and partially owned subsidiaries in these lines along with the need
    to describe changes to the list each year. In addition, it does not
    seem to GE that such data is pertinent given the purpose of the
    program. GE recommends that DOE limit this line to large
    subsidiaries that are major structural units at the top second or
    third tier of the corporation. In addition, GE could provide a list
    of large controlled sites included within the inventory, as it has
    in the past.

6.  \[Form Item 9\] This item asks the reporting entity to enter a code
    and primary NAICS code for each country included within its GHG
    Inventory. First, DOE must provide for numerous entries in these
    lines for large corporations such as GE, which included 69 countries
    in its 2004 GHG Inventory. Second, the entry of a primary NAICS code
    for each country is not meaningful for GE. Many of GE's operating
    units operate in the same foreign country so that GE will have
    numerous NAICS codes in many countries. It will be difficult to
    separate out a single primary NAICS code for each country. In
    addition, GE questions why DOE needs information on NAICS codes in
    each country where GE operates.

7.  \[Instructions\] It would be helpful for DOE to expand its
    instructions for Schedule I to better communicate what information
    it expects and needs to receive.

8.  \[Instructions Item 7\] This instruction is confusing in that it
    directs the reporting entity to enter the name of its parent or
    holding company if it is itself a holding company. The Form Item 7
    is clear in that "Is your company a holding company" and "Identity
    your entity's Parent or Holding Company, if applicable" are two
    separate and unrelated questions. The instruction should be revised
    to separate the connection between the two questions.

9.  \[Instructions and Form Item 8\] The Instruction and Form appear to
    be inconsistent for Item 8 in that the Instructions direct the
    reporting entity to check either "Financial Control" or "Other" if a
    method other than Financial Control is used and the Form provides
    "Financial Control", "Operational Control" and "Other". GE uses
    operational control to set operational boundaries, and therefore
    suggests that the Form Item 8 is correct. Therefore, the
    Instructions should be revised to make them consistent with the
    Form.

Schedule II

1.  \[Form Item 2\] A check box should be added for "Other, Please
    Explain" since the items provided may not provide all the potential
    reasons for delineating a subentity. According to the General
    Instructions, "A subentity is a component of any entity, such as a
    discrete business line, facility, plant, vehicle fleet, or energy
    using system, which has greenhouse gases that can be distinguished
    from the emissions of all other components of the same entity." A
    reporting entity may choose to separate out various subentities to
    improve the transparency of their GHG Inventory submittal. For
    example, GE operates both industrial manufacturing facilities and
    electricity generating units. GE may choose to separate these types
    of facilities to provide more transparency in our GHG Inventory
    reporting. Reporting entities should not be limited to only the
    reasons provided in Item 2 of Schedule II.

Schedule III

1.  \[Form All Sections and Parts\] The Instructions and the form should
    be clarified to indicate whether DOE expects data to be presented in
    units of the base gas or in units of CO2 equivalents. For example
    should 1 metric ton of HFC-134a be reported as 1 metric ton of
    HFC-134a or 1,300 metric tons of CO2 equivalents?

2.  \[Form Section 1 -- Part A 1\] This section appropriately combines
    CO2 emissions from all fossil fuel combustion into a single line
    item. However, DOE should note that a reporting entity might use
    different types of estimation methods with different ratings with
    different types of fuels and even for different types of sources
    using the same fuel. A reporting entity will have to combine data
    including the preparation of a weighted average rating before
    entering data into Part A 1. In addition, a reporting entity may
    have to enter a list of estimation methods in the single line for
    CO2 emissions.

3.  \[Form Section 1 -- Part A 1\] As stated above under the first
    comment for Schedule I, GE's 2004 baseline year was established
    before the final General and Technical Guidelines were available.
    Because of this, GE will not be able to submit a "Start Year" report
    and the base year emissions listed in Schedule III will not have
    been prepared in conformance with the final General and Technical
    Guidelines.

4.  \[Form Section 1 -- Part A3\] Another line ("Other Industrial
    Processes") should be added here for those industrial processes that
    do not fall under any of the listed processes. None of GE's
    industrial process emissions fall under the listed processes.

Schedule IV

1.  No Comments.

Schedule V

1.  \[Form Section 1 -- Part A.1\] Part A.1 calculates emission
    intensity reductions separately for direct and indirect emissions.
    Many companies that have set emission intensity reduction goals have
    set then for the combination of direct and indirect emissions
    instead of setting them separately. Therefore another column should
    be included to report the combined emission intensity reductions
    that includes both direct and indirect emissions.

2.  \[Form Section 1 -- Part A.3\] The calculation shown in this section
    does not correctly account for changes in intensity used by many
    companies that have stated intensity reduction goals. DOE should use
    the following calculation:

> CIT = A -- B
>
> Where:
>
> CIT = Change in Intensity
>
> A = Base Year Intensity
>
> B = Current Year Intensity
>
> Or if the percent change is needed:
>
> CIT = \[(A - B) / A\] x 100%
>
> The multiplication of the base year intensity times the current year
> output, as is done in the equation in the Form, has no meaning. It
> appears that DOE is attempting to convert the emission intensity
> approach to an absolute approach so that all of the emission
> reductions from the various methods can be combined into a single
> reduction in Schedule VI. If this is what DOE wants to do, then DOE
> should convert the intensity reduction to the true absolute reduction
> using the following equation:
>
> CIT~absolute~ = (A x C) -- (B x D)
>
> Where:
>
> CIT~absolute~ = Absolute reduction associated with the intensity
>
> Reduction
>
> A = Base Year Intensity
>
> B = Current Year Intensity
>
> C = Base Year Output
>
> D = Current Year Output

3.  Form Section 1 -- Part B.1\] This item states that Part A (Intensity
    Reductions) must be used if the change in output entered is a
    negative number. GE argued in its comments on the Interim Final
    General Guidelines that a reporting entity should still be permitted
    to use the absolute reduction approach if its output has decreased
    if it can show that all or part of its absolute reduction did not
    result from a decrease in output. In addition, GE argued that
    absolute reductions resulting from plant closings were real
    reductions and should be reported and registered in the 1605b
    program. In addition, GE suggests that DOE remove the requirement
    that the output must not decrease for each separately listed
    subentity before the absolute reduction approach can be used for
    each subentity. As noted above in our comments on the General
    Instructions, it appears that GE will be required to submit separate
    entity statements for each of 69 countries. GE needs to use the
    absolute approach throughout to report emission changes for
    comparison against our GHG emission reduction goal that is stated in
    absolute terms. Therefore, GE would use the absolute approach for
    all countries. However, it is unlikely that all countries will
    always show an increase in output. Production and sales will always
    be changing from country to country within the full GE entity. As
    output decreases in one country, it will increase in other
    countries. It should be sufficient for the reporting entity to
    demonstrate that the entity wide output has not decreased instead of
    demonstrating that the output has not decreased for each subentity.

4.  \[Form Section 1 -- Part B.2\] Part B.2 calculates absolute emission
    reductions separately for direct and indirect emissions. Many
    companies that have set absolute emission reduction goals have set
    then for the combination of direct and indirect emissions instead of
    setting them separately. Therefore another column should be included
    to report the combined absolute emissions that includes both direct
    and indirect emissions.

5.  \[Form Section 2\] Section 2 of Schedule V appears to require the
    reporting entity to essentially submit a complete 1605b report for
    each entity providing any offsets, requiring much more information
    than is necessary given the purposes of the program. Information on
    the project that is providing the offset such as a description of
    the project, the emissions before the project, the emissions after
    the project, the emissions reduction, and demonstration of the legal
    basis for transferring the reductions from the project owner to the
    reporting entity should be sufficient. The requirement for a
    reporting entity to submit an essentially full 1605b report for each
    offset provider will place a very significant and unnecessary burden
    on the reporting entity and will be a significant disincentive
    against the reporting of reductions.

Schedule VI

1.  \[Form Section 1 Part A -- C\] Section 1 Parts A -- C attempt to
    combine the emission reductions from all calculation methods into a
    single reduction number. However, the inputs from the calculation
    methods are not the same (apples and oranges) and cannot be
    combined. For example the input from the emission intensity
    reduction calculated from Schedule V is a meaningless number that
    multiplies the change in intensity times the current year activity
    as explained above in Comment No. 2 for Schedule V. All emission
    reductions from all methods should be converted to true absolute
    values before they can be combined in Schedule VI to calculate a
    total entity wide value.

Schedule VII

1.  \[Form Section 2.2\] A reporting entity that participates in
    activities with other owners cannot certify that "None of the direct
    emissions, direct emission reductions, or sequestration reported in
    this 1605b report are included in the 1605b report of any other
    entity for the same calendar year." This certification language is
    inconsistent with language contained in the Interim Final General
    Guidelines and is totally inappropriate, as discussed above in our
    third and fourth comments under "General Comments."

2.  \[Form Section 2.2\] The first certification header statement should
    be clarified to read, "This form meets the following three
    requirements for reporting [of emission or]{.underline} reductions,"
    to clarify that a reporting entity that is only reporting GHG
    emissions still needs to certify to the first three certification
    statements.

3.  \[Form Section 2.2\] The form does not provide a mechanism for a
    certifying official to indicate whether the certification signature
    applies only to the first three certification statements for the
    reporting of emissions and reductions or that it applies to all
    eight certification statements for the registration of reductions in
    the PDF version of the revised Form EIS -- 1605 that was downloaded
    from the DOE web site. This may lead to confusion concerning the
    scope of a certification. The form should provide a way for the
    certifying official to affirmatively indicate the scope of the
    certification. One approach would be to separate the certification
    for reporting and registration. The reporting certification would
    include the three certification statements followed by a signature
    block while the registration certification would include the eight
    certification statements followed by a separate signature block.
    This would allow the certifying official to clearly indicate which
    certification is being made.