Working Paper (revised 5/14/02**)**

**Greenhouse Gas Registry Issues Analysis**

President Bush's Global Climate Change Initiative identified three
objectives for an enhanced national registry: (1) achieve a high level
of confidence in the reductions recorded in the registry, through
enhanced "measurement accuracy, reliability, and verifiability"; (2)
promote the identification and expansion of innovative and effective
ways to reduce ghg's; and, (3) encourage participation, by removing the
risks that reporting entities could be "penalized under a future climate
change policy" (*i.e*., baseline protection), and by giving
"transferable credits to companies that can show real emissions
reductions."

Based on the 2000 EIA report, 103 entities from the electric power
industry provided § 1605(b) reports, covering about two thirds of the
ghg emissions of the electric power sector.

The analysis below summarizes the significant provisions of the existing
§ 1605(b) guidelines and identifies issues and potential changes
required to achieve an enhanced national registry. The issues and
potential changes are qualified based upon their relationship to the
three policy objectives, namely ***improved reporting; creative ways to
reduce ghg's; and baseline protection, transferable credits and credit
for prior action***. The provisions of S. 517, as originally introduced
by Senators Daschle and Bingaman, are also described for comparative
purposes and as a marker for more extreme or radical changes.

In describing S. 517, it is first important to note that while the bill
sets forth fairly detailed and specific requirements, it also
contemplates that many of the rules and procedures will be developed
through agency rulemakings. Accordingly, we do not know yet what will be
required with regard to such issues as verification, additionality, etc.
Second, unlike the 1605(b) program, which is entirely under the control
of DOE, under S. 517 responsibilities for various database issues are
shared among DOE, Commerce and EPA. For example, S. 517 provides that
EPA will have primary responsibility for emissions monitoring,
verification and data collection.

While there are several areas in which the EIA registry and 1605(b)
guidelines may be improved, the system is functioning, and many aspects
of the current registry and guidelines should be maintained.

This analysis is a "living document" and is expected to evolve over
time. Finally, it should be noted that all members of the electric power
sector do not necessarily endorse the potential changes identified in
this paper.

**I. BASIC PROVISIONS AND DEFINITIONS**

+----------+------------------+-------------------+------------------+
|          | **Existing       | *                 | **S. 517 (as     |
|          | 1605(b)          | *Issues/Potential | introduced)**    |
|          | Reporting**      | Changes for       |                  |
|          |                  | Enhanced          |                  |
|          |                  | Registry**        |                  |
+==========+==================+===================+==================+
| **De     | U.S. citizen,    | *For reporting    | A person located |
| finition | resident alien,  | purposes*, no     | in the U.S. or a |
| of       | or organization  | change required.  | public or        |
| R        | incorporated or  | *For transferable | private entity   |
| eporting | recognized by    | credits*,         | that operates in |
| Entity** | U.S. law, or any | ownership of      | the U.S.         |
|          | governmental     | reductions        |                  |
|          | entity. Third    | reported by       |                  |
|          | party (*e.g*.,   | other/third       |                  |
|          | trade            | parties and joint |                  |
|          | association) and | reporting need to |                  |
|          | joint reporting  | be clarified.     |                  |
|          | also available.  |                   |                  |
+----------+------------------+-------------------+------------------+
| **Types  | Carbon dioxide   | *For reporting    | Carbon dioxide   |
| of       |                  | purposes*, no     |                  |
| Gree     | Methane          | change required.  | Methane          |
| nhouse** |                  | *For transferable |                  |
|          | Nitrous oxide    | credits*, NO~x~,  | Nitrous oxide    |
| **Gases  |                  | VOC, and CO could |                  |
| Included | Hy               | be excluded.      | Hy               |
| in the   | drofluorocarbons |                   | drofluorocarbons |
| Da       |                  |                   |                  |
| tabase** | Perfluorocarbons |                   | Perfluorocarbons |
|          |                  |                   |                  |
|          | Sulfur           |                   | Sulfur           |
|          | hexafluoride     |                   | hexafluoride     |
|          |                  |                   |                  |
|          | Nitrogen oxides  |                   |                  |
|          |                  |                   |                  |
|          | Nonmethane       |                   |                  |
|          | volatile         |                   |                  |
|          | organics         |                   |                  |
|          |                  |                   |                  |
|          | Carbon monoxide  |                   |                  |
+----------+------------------+-------------------+------------------+
| **Des    | GHG emission     | No change         | GHG emission     |
| cription | from a source    | required.         | from a source    |
| of       | that is owned or |                   | that is owned or |
| Direct   | controlled by an |                   | controlled by an |
| Emi      | entity. Direct   |                   | entity.          |
| ssions** | emissions result |                   |                  |
|          | directly from    |                   |                  |
|          | fuel combustion  |                   |                  |
|          | or other         |                   |                  |
|          | processes that   |                   |                  |
|          | release GHG's on |                   |                  |
|          | site.            |                   |                  |
+----------+------------------+-------------------+------------------+
| **Des    | GHG emissions    | *For reporting    | GHG emissions    |
| cription | that are a       | purposes*,        | that are a       |
| of       | consequence of   | additional        | consequence of   |
| Indirect | an entity, but   | guidance may be   | an entity, but   |
| Emi      | are emitted by   | needed to         | are emitted by   |
| ssions** | other entities.  | identify          | other entities,  |
|          | Indirect         | duplicative       | and are not      |
|          | emissions are    | reporting. *For   | reported as      |
|          | produced when    | baseline          | direct emissions |
|          | activities cause | protection and*   | by a covered     |
|          | emissions to be  | *for transferable | entity.          |
|          | generated        | credits*,         |                  |
|          | elsewhere.       | additional        |                  |
|          |                  | guidelines may be |                  |
|          |                  | needed to prevent |                  |
|          |                  | duplicative       |                  |
|          |                  | reports of        |                  |
|          |                  | indirect          |                  |
|          |                  | emissions.        |                  |
+----------+------------------+-------------------+------------------+
| **Carbon | The sectoral     | *For reporting    | Includes         |
| Sequest  | guidelines for   | purposes,         | capture,         |
| ration** | forestry and     | baseline          | long-term        |
|          | agriculture      | protection and    | separation,      |
|          | discuss in       | transferable      | isolation, or    |
|          | detail key       | credits,*         | removal of GHG   |
|          | issues relating  | additional        | from the         |
|          | to forestry      | guidance is       | atmosphere,      |
|          | projects,        | needed on three   | including        |
|          | including        | issues: (1)       | biological or    |
|          | measurement,     | establishing      | geological       |
|          | monitoring,      | baselines, (2)    | methods such as  |
|          | verification,    | measurement of    | reforestation or |
|          | baselines, etc.  | sequest           | an underground   |
|          | Specific         | ration/emissions, | reservoir.       |
|          | examples are     | and (3) timing    |                  |
|          | provided,        | issues (*i.e.*,   |                  |
|          | although         | permanence).      |                  |
|          | concrete         |                   |                  |
|          | guidelines are   |                   |                  |
|          | lacking. The     |                   |                  |
|          | general          |                   |                  |
|          | guidelines       |                   |                  |
|          | discuss          |                   |                  |
|          | particular       |                   |                  |
|          | aspects of       |                   |                  |
|          | forestry         |                   |                  |
|          | projects and     |                   |                  |
|          | provide an       |                   |                  |
|          | example.         |                   |                  |
+----------+------------------+-------------------+------------------+

**II. GHG EMISSIONS INVENTORY**

+----------+------------------+-------------------+------------------+
|          | **Existing       | *                 | **S. 517 (as     |
|          | 1605(b)          | *Issues/Potential | introduced)**    |
|          | Reporting**      | Changes for       |                  |
|          |                  | Enhanced          |                  |
|          |                  | Registry**        |                  |
+==========+==================+===================+==================+
| *        | Voluntary        | No change         | Mandatory        |
| *Partici |                  | required.         |                  |
| pation** |                  |                   |                  |
+----------+------------------+-------------------+------------------+
| **Scope  | Either specific  | *For reporting    | Facility level,  |
| of       | facilities or    | purposes,* no     | aggregated       |
| Repor    | entity level.    | change required.  | entity-wide.     |
| ting/Bas | Entity reports   | *For transferable | Definition of    |
| elines** | need not cover   | credits,*         | facility         |
|          | all facilities.  | additional        | includes a fleet |
|          | (About half of   | guidelines may be | of 20 or more    |
|          | current reports  | needed to ensure  | transportation   |
|          | are entity-wide; | that transferable | vehicles.        |
|          | the other half   | credits are not   |                  |
|          | are facility or  | provided for      |                  |
|          | project level.)  | reductions that   |                  |
|          |                  | may have          |                  |
|          | \[Determine how  | offsetting        |                  |
|          | this relates to  | "leakage."        |                  |
|          | CAA section      |                   |                  |
|          | 821.\]           | Ownership may     |                  |
|          |                  | also be an issue. |                  |
+----------+------------------+-------------------+------------------+
| **T      | Since all        | *For reporting    | Provision        |
| hreshold | reporting is     | purposes*, no     | covering 75% of  |
| for      | voluntary, the   | change required.  | all emissions    |
| R        | guidelines do    | Establishment of  | expands two      |
| eporting | not specify a    | a minimum or      | lesser tests:    |
| (minimum | minimum or       | threshold for     | (1) total GHG    |
| or       | threshold for    | reporting becomes | emissions exceed |
| t        | reporting        | an issue (1)      | 10,000 MT CO2    |
| hreshold | purposes.        | under mandatory   | equivalent at at |
| for      |                  | reporting regime  | least one        |
| repo     |                  | or (2) if there   | facility, or (2) |
| rting)** |                  | are required      | total quantity   |
|          |                  | elements if an    | of GHG's         |
|          |                  | entity chooses to | produced,        |
|          |                  | report.           | distributed or   |
|          |                  |                   | imported exceeds |
|          |                  |                   | 10,000 MT CO2    |
|          |                  |                   | equivalent.      |
+----------+------------------+-------------------+------------------+
| **Extent | The current      | *For reporting    |                  |
| of       | guidelines do    | purposes*, no     |                  |
| Report   | not specify      | change required.  |                  |
| for      | criteria for     | *For both         |                  |
| Ent      | full entity-wide | baseline          |                  |
| ity-wide | reporting.       | protection and    |                  |
| (or      |                  | transferable      |                  |
| Facili   |                  | credits,* where   |                  |
| ty-wide) |                  | an entity wishes  |                  |
| Rep      |                  | to obtain         |                  |
| orting** |                  | recognition for   |                  |
|          |                  | entity-wide       |                  |
|          |                  | reports,          |                  |
|          |                  | additional        |                  |
|          |                  | guidelines may be |                  |
|          |                  | needed to allow   |                  |
|          |                  | entities (or      |                  |
|          |                  | facilities) to    |                  |
|          |                  | exclude *de       |                  |
|          |                  | minimis* sources. |                  |
|          |                  | Rationale:        |                  |
|          |                  | reporting burden  |                  |
|          |                  | exceeds potential |                  |
|          |                  | value of          |                  |
|          |                  | information.      |                  |
+----------+------------------+-------------------+------------------+
| **Total  | Current          | *For reporting    | Yes, direct,     |
| E        | guidelines allow | purposes,* no     | indirect         |
| missions | reporting of any | change required.  | (including       |
| Rep      | or all           | *For both         | outsourced       |
| orting** | emissions,       | baseline          | activities and   |
|          | including direct | protection and    | of electricity,  |
|          | and indirect     | transferable      | heat and steam), |
|          | emissions.       | credits,*         | direct emissions |
|          |                  | entities may need | from land use    |
|          |                  | to report direct  | activities that  |
|          |                  | and indirect      | release          |
|          |                  | emissions, but in | significant      |
|          |                  | this case         | quantities of    |
|          |                  | additional        | GHG, others as   |
|          |                  | guidelines may be | determined by    |
|          |                  | needed to clarify | rule.            |
|          |                  | the types of      |                  |
|          |                  | indirect          |                  |
|          |                  | emissions to be   |                  |
|          |                  | reported.         |                  |
|          |                  | \[subject to      |                  |
|          |                  | further review\]  |                  |
|          |                  |                   |                  |
|          |                  | See also Extent   |                  |
|          |                  | of Report for     |                  |
|          |                  | Entity-wide       |                  |
|          |                  | Reporting row     |                  |
|          |                  | above.            |                  |
+----------+------------------+-------------------+------------------+
| **E      | Not specified.   | *For reporting    | Required;        |
| missions |                  | purposes,         | specific         |
| Int      |                  | baseline          | emissions        |
| ensity** |                  | protection and    | intensity        |
|          |                  | transferable      | measures to be   |
| **Rep    |                  | credits,* no      | determined by    |
| orting** |                  | provision for     | rule.            |
|          |                  | reporting on a    |                  |
|          |                  | emissions         |                  |
|          |                  | intensity basis   |                  |
|          |                  | is required,      |                  |
|          |                  | since the         |                  |
|          |                  | Administration's  |                  |
|          |                  | policy goal is    |                  |
|          |                  | set on an         |                  |
|          |                  | aggregate, not    |                  |
|          |                  | sector- or        |                  |
|          |                  | entity-specific   |                  |
|          |                  | basis. However,   |                  |
|          |                  | the revised       |                  |
|          |                  | guidelines should |                  |
|          |                  | allow flexibility |                  |
|          |                  | for entities to   |                  |
|          |                  | report emissions  |                  |
|          |                  | intensity         |                  |
|          |                  | measures in       |                  |
|          |                  | addition to total |                  |
|          |                  | emissions.        |                  |
+----------+------------------+-------------------+------------------+

**III. REPORTING OF GHG EMISSIONS REDUCTIONS**

+----------+------------------+-------------------+------------------+
|          | **Existing       | *                 | **S. 517 (as     |
|          | 1605(b)          | *Issues/Potential | introduced)**    |
|          | Reporting**      | Changes for       |                  |
|          |                  | Enhanced          |                  |
|          |                  | Registry**        |                  |
+==========+==================+===================+==================+
| *        | Voluntary        | In furtherance of | While reporting  |
| *Partici |                  | the Bush climate  | of project-based |
| pation** |                  | plan's second     | reductions is    |
|          |                  | objective, allow  | voluntary, the   |
|          |                  | a broader range   | reporting of     |
|          |                  | of reportable     | entity emissions |
|          |                  | activities and    | is mandatory.    |
|          |                  | provide           | Also, not        |
|          |                  | flexibility in    | everything       |
|          |                  | how projects are  | voluntarily      |
|          |                  | reported.         | reported will    |
|          |                  |                   | necessarily be   |
|          |                  |                   | included in the  |
|          |                  |                   | registry,        |
|          |                  |                   | depending on the |
|          |                  |                   | verification     |
|          |                  |                   | rules, etc.      |
+----------+------------------+-------------------+------------------+
| **Types  | The general      | The second bullet | Fuel switching,  |
| of       | guidelines       | should be         | efficiency       |
| Repo     | provide broad    | modified to say   | improvements,    |
| rtable** | criteria. An     | "Results in       | renewable        |
|          | entity           | reducing or       | energy, CHP,     |
| **Acti   | initiates,       | avoiding GHG      | forestry         |
| vities** | controls or      | emissions."       | activities that  |
|          | participates in  |                   | increase sinks   |
|          | any activity     | Question: is more | or reduce forest |
|          | that:            | specificity on    | carbon           |
|          |                  | types of          | emissions,       |
|          | -   Contributes  | reportable        | carbon capture,  |
|          |     to GHG       | activities        | methane          |
|          |     emissions,   | desirable, such   | recovery, carbon |
|          |                  | as sequestration? | offsets.         |
|          | -   Results in   |                   |                  |
|          |     reducing GHG |                   |                  |
|          |     emissions,   |                   |                  |
|          |     or           |                   |                  |
|          |                  |                   |                  |
|          | -   Sequesters   |                   |                  |
|          |     carbon.      |                   |                  |
|          |                  |                   |                  |
|          | The              |                   |                  |
|          | sector-specific  |                   |                  |
|          | guidelines       |                   |                  |
|          | provide further  |                   |                  |
|          | detailed         |                   |                  |
|          | descriptions and |                   |                  |
|          | examples of      |                   |                  |
|          | types of         |                   |                  |
|          | reportable       |                   |                  |
|          | activities.      |                   |                  |
|          | \[elaborate      |                   |                  |
|          | elsewhere\]      |                   |                  |
+----------+------------------+-------------------+------------------+
| **Scope  | Any or all       | *For reporting    | Direct           |
| of       | direct or        | purposes,* no     | emissions,       |
| R        | indirect         | change required.  | indirect         |
| eporting | emissions,       | *For transferable | emissions not    |
| (emis    | including        | credits*,         | otherwise        |
| sions)** | sequestration,   | additional        | reported, and    |
|          | at the project   | guidelines may be | product use      |
|          | level.           | necessary to      | phase emissions. |
|          |                  | prevent           |                  |
|          |                  | duplication of    |                  |
|          |                  | transferable      |                  |
|          |                  | credits for       |                  |
|          |                  | indirect          |                  |
|          |                  | emissions.        |                  |
+----------+------------------+-------------------+------------------+
| **Inter  | Includes         | *For reporting    | Includes         |
| national | reporting of     | purposes,* no     | project-based    |
| Emission | project-based    | change required.  | reductions and   |
| Redu     | reductions       | *For transferable | transfers of     |
| ctions** | outside the U.S. | credits,* the     | project-based    |
|          | Must indicate if | registry should   | reductions       |
|          | the project is   | provide maximum   | outside the U.S. |
|          | part of USIJI or | flexibility for   |                  |
|          | the Framework    | recognizing       |                  |
|          | Convention on    | overseas          |                  |
|          | Climate Change.  | reductions.       |                  |
|          |                  | First, it needs   |                  |
|          |                  | to provide for    |                  |
|          |                  | review and        |                  |
|          |                  | recognition of    |                  |
|          |                  | project-based     |                  |
|          |                  | international     |                  |
|          |                  | emission          |                  |
|          |                  | reductions.       |                  |
|          |                  | Second, the       |                  |
|          |                  | registry should   |                  |
|          |                  | automatically     |                  |
|          |                  | recognize         |                  |
|          |                  | emission          |                  |
|          |                  | reduction units,  |                  |
|          |                  | allowances or     |                  |
|          |                  | credits obtained  |                  |
|          |                  | from other        |                  |
|          |                  | national or       |                  |
|          |                  | international     |                  |
|          |                  | climate change    |                  |
|          |                  | programs (*e.g.,* |                  |
|          |                  | U.K. allowances;  |                  |
|          |                  | Kyoto Protocol    |                  |
|          |                  | CER's, ERU's,     |                  |
|          |                  | etc.).            |                  |
+----------+------------------+-------------------+------------------+
| **B      | The guidelines   | A 2002 baseline   | See              |
| aselines | allows for       | was used in       | Additionality    |
| and      | reporting of     | establishing the  | row below.       |
| Baseline | reductions       | national goal of  |                  |
| Prot     | relative to one  | reducing GHG      | S. 517 does not  |
| ection** | of two           | intensity by 18%  | appear to        |
|          | baselines:       | over 10 years.    | address baseline |
|          |                  | *For baseline     | protection.      |
|          | -   Basic        | protection*, a    |                  |
|          |     Reference    | uniform baseline  |                  |
|          |     Case:        | could provide     |                  |
|          |     reductions   | unambiguous       |                  |
|          |     relative to  | protection for    |                  |
|          |     historic     | equivalent        |                  |
|          |     levels, but  | values. However,  |                  |
|          |     no earlier   | since no specific |                  |
|          |     than 1987.   | baseline has yet  |                  |
|          |                  | been established  |                  |
|          | -   Modified     | for purposes of   |                  |
|          |     Reference    | baseline          |                  |
|          |     Case:        | protection and    |                  |
|          |     reductions   | transferable      |                  |
|          |     relative to  | credits, multiple |                  |
|          |     projected    | (or flexible)     |                  |
|          |     future       | baselines should  |                  |
|          |     emissions    | be allowed, so    |                  |
|          |     levels in    | long as clear     |                  |
|          |     the absence  | methodologies are |                  |
|          |     of the       | established for   |                  |
|          |     project.     | each.             |                  |
|          |                  |                   |                  |
|          | Currently,       |                   |                  |
|          | virtually all    |                   |                  |
|          | project-level    |                   |                  |
|          | reports and      |                   |                  |
|          | about 80% of     |                   |                  |
|          | entity-wide      |                   |                  |
|          | reports use a    |                   |                  |
|          | modified         |                   |                  |
|          | reference case.  |                   |                  |
|          |                  |                   |                  |
|          | The guidelines   |                   |                  |
|          | do not           |                   |                  |
|          | specifically     |                   |                  |
|          | address baseline |                   |                  |
|          | protection.      |                   |                  |
+----------+------------------+-------------------+------------------+
| **Rec    | The guidelines   | *For reporting    | Transition       |
| ognition | established      | purposes,         | provision:       |
| for      | 1987-1990 as the | baseline          | entities may     |
| Re       | base year        | protection and    | report           |
| ductions | period. The      | transferable      | reductions       |
| Achieved | guidelines       | credits*,         | implemented      |
| and/or   | established the  | entities should   | prior to         |
| Reported | principle that   | be allowed to     | enactment if     |
| Prior to | reductions from  | report and        | they were        |
| Adoption | pre-1987         | receive credit    | registered under |
| of New   | activities could | for reductions    | 1605(b) and meet |
| R        | be reported if   | from pre-2002     | verification     |
| eporting | the prior        | activities.       | rules developed  |
| Prov     | activities       | Failure to        | pursuant to S.   |
| isions** | resulted in      | provide such      | 517. However, S. |
|          | increasing       | recognition would | 517 does not     |
|          | reductions over  | create a strong   | appear to        |
|          | time (*i.e*.,    | disincentive for  | provide any form |
|          | prior year       | entities to       | of transferable  |
|          | actions that     | report reductions | credit for any   |
|          | have achieved    | in the            | reductions,      |
|          | steady state     | expectation of    | early or         |
|          | reductions by    | obtaining future  | otherwise.       |
|          | 1990 are         | baseline          |                  |
|          | considered part  | protection or     |                  |
|          | of the baseline  | transferable      |                  |
|          | and are not      | credits. Fair and |                  |
|          | eligible).       | reasonable        |                  |
|          |                  | transition        |                  |
|          | The general      | provisions need   |                  |
|          | guidelines       | to be developed.  |                  |
|          | permit revision  | (Transition       |                  |
|          | of past reports. | provisions could  |                  |
|          |                  | be based upon (1) |                  |
|          |                  | demonstrating     |                  |
|          |                  | compliance with   |                  |
|          |                  | the revised       |                  |
|          |                  | 1605(b)           |                  |
|          |                  | guidelines and    |                  |
|          |                  | achieving         |                  |
|          |                  | increasing        |                  |
|          |                  | reductions over   |                  |
|          |                  | time, or (2)      |                  |
|          |                  | meeting           |                  |
|          |                  | retroactively     |                  |
|          |                  | applied           |                  |
|          |                  | verification      |                  |
|          |                  | provisions.)      |                  |
|          |                  |                   |                  |
|          |                  | (20-25% of        |                  |
|          |                  | current reporting |                  |
|          |                  | uses the 1605-EZ  |                  |
|          |                  | Form, which has   |                  |
|          |                  | insufficient      |                  |
|          |                  | detail to enable  |                  |
|          |                  | any type of       |                  |
|          |                  | transition        |                  |
|          |                  | provision         |                  |
|          |                  | determination.)   |                  |
+----------+------------------+-------------------+------------------+
| **Joint  | Entities are     | No change         | No specific      |
| R        | permitted to     | required.         | provisions.      |
| eporting | jointly report   |                   | (Joint reporting |
| by       | reductions. The  |                   | addressed        |
| Multiple | guidelines       |                   | indirectly       |
| En       | request that the |                   | through the      |
| tities** | entities provide |                   | requirements     |
|          | an allocation of |                   | regarding        |
|          | the reduction    |                   | reporting of     |
|          | using their own  |                   | indirect         |
|          | methodology, or  |                   | emissions and    |
|          | using ownership  |                   | duplication of   |
|          | shares as the    |                   | reductions.)     |
|          | default.         |                   |                  |
+----------+------------------+-------------------+------------------+
| **Dup    | Reporting        | *For reporting    | Requires DOE to  |
| lication | entities are     | purposes*,        | develop a        |
| of       | encouraged to    | *baseline         | protocol to      |
| Reported | identify areas   | protection and    | "prevent the     |
| Redu     | of potential     | transferable      | reporting of . . |
| ctions** | duplication in   | credits*,         | . reductions by  |
|          | reports. No      | additional        | more than one    |
|          | requirement to   | guidelines are    | reporting        |
|          | exclude          | needed to prevent | entity."         |
|          | duplicative      | duplication of    |                  |
|          | reductions from  | reported          |                  |
|          | the registry.    | reductions.       |                  |
+----------+------------------+-------------------+------------------+
| **O      | The guidelines   | *For reporting    | Additional       |
| wnership | do not           | purposes,* no     | provision allows |
| of       | specifically     | change required.  | for change in    |
| Reported | address          | *For both         | registration of  |
| Re       | ownership        | baseline          | ownership of     |
| ductions | issues, and      | protection and    | reductions.      |
| and      | implicitly       | transferable      |                  |
| Transfer | assume that the  | credits*,         |                  |
| of       | reporting entity | additional        |                  |
| Own      | is the owner.    | guidelines are    |                  |
| ership** |                  | needed to         |                  |
|          |                  | designate         |                  |
|          |                  | ownership and     |                  |
|          |                  | ownership         |                  |
|          |                  | transfers.        |                  |
|          |                  | (Ownership could  |                  |
|          |                  | be assigned to    |                  |
|          |                  | the reporting     |                  |
|          |                  | entity, the owner |                  |
|          |                  | of the emissions  |                  |
|          |                  | source, or the    |                  |
|          |                  | entity that       |                  |
|          |                  | causes the        |                  |
|          |                  | reduction to      |                  |
|          |                  | occur, including  |                  |
|          |                  | funding. Also,    |                  |
|          |                  | allocation of     |                  |
|          |                  | reductions by     |                  |
|          |                  | contract is       |                  |
|          |                  | possible.)        |                  |
+----------+------------------+-------------------+------------------+
| *        | No demonstration | No change         | Reductions must  |
| *Additio | of additionality | required.         | be relative to   |
| nality** | required. Under  | Financial         | historic         |
|          | 1605(b)(1)(C),   | additionality     | emissions levels |
|          | reductions in    | should be         | and net of any   |
|          | GHG emissions    | opposed.          | increase in      |
|          | can be achieved  |                   | direct and       |
|          | as a result of:  |                   | indirect         |
|          |                  |                   | emissions.       |
|          | -   Voluntary    |                   | Sequestration    |
|          |     reductions,  |                   | must be actual   |
|          |                  |                   | increases in net |
|          | ```{=html}       |                   | sequestration.   |
|          | <!-- -->         |                   |                  |
|          | ```              |                   |                  |
|          | -   Plant or     |                   |                  |
|          |     facility     |                   |                  |
|          |     closings, or |                   |                  |
|          |                  |                   |                  |
|          | -   State or     |                   |                  |
|          |     federal      |                   |                  |
|          |                  |                   |                  |
|          |    requirements. |                   |                  |
+----------+------------------+-------------------+------------------+
| **L      | No demonstration | *For reporting    | Reported         |
| eakage** | required         | purposes,* no     | reductions must  |
|          |                  | change required.  | be net of any    |
|          |                  | *For both         | increases in     |
|          |                  | baseline          | direct and       |
|          |                  | protection and    | indirect         |
|          |                  | transferable      | emissions.       |
|          |                  | credits*,         |                  |
|          |                  | additional        |                  |
|          |                  | guidelines are    |                  |
|          |                  | needed to assure  |                  |
|          |                  | that reported     |                  |
|          |                  | reductions do not |                  |
|          |                  | result in         |                  |
|          |                  | leakage.          |                  |
+----------+------------------+-------------------+------------------+

**IV. VERIFICATION AND OTHER ISSUES**

+----------+------------------+-------------------+------------------+
|          | **Existing       | *                 | **S. 517 (as     |
|          | 1605(b)          | *Issues/Potential | introduced)**    |
|          | Reporting**      | Changes for       |                  |
|          |                  | Enhanced          |                  |
|          |                  | Registry**        |                  |
+==========+==================+===================+==================+
| **Data   | The guidelines   | # For r           | Agencies to      |
| Q        | define and allow | eporting purposes | develop protocol |
| uality** | three types of   | , no change neede | to prevent       |
|          | data to be used  | d. For both basel | double counting, |
| **Prov   | to describe      | ine protection an | procedures for   |
| isions** | emissions        | d transferable cr | corrections and  |
|          | reductions       | edits, the 1605-E | adjustments,     |
|          | activities and   | Z Form may not be | changes in       |
|          | estimate         |  appropriate. Oth | ownership due to |
|          | emission         | er changes may be | trading, changes |
|          | impacts:         |  needed for data  | in methods for   |
|          |                  | quality purposes. | measuring or     |
|          | -   Physical     |                   | calculating GHG  |
|          |     data         | See also          | emissions.       |
|          |     describing   | Duplication of    |                  |
|          |     the project, | Reported          |                  |
|          |                  | Reductions row in |                  |
|          | -   Default data | section III       |                  |
|          |     (*e.g.,*     | above.            |                  |
|          |     emissions    |                   |                  |
|          |     factors)     |                   |                  |
|          |     that allow   |                   |                  |
|          |     estimates of |                   |                  |
|          |     GHG efforts, |                   |                  |
|          |     and          |                   |                  |
|          |                  |                   |                  |
|          | -   Data         |                   |                  |
|          |     generated by |                   |                  |
|          |     the          |                   |                  |
|          |     reporting    |                   |                  |
|          |     entity       |                   |                  |
|          |     (either      |                   |                  |
|          |     measured     |                   |                  |
|          |     data or      |                   |                  |
|          |     engineering  |                   |                  |
|          |     data).       |                   |                  |
|          |                  |                   |                  |
|          | The guidelines   |                   |                  |
|          | allow for        |                   |                  |
|          | amendments to    |                   |                  |
|          | reports to       |                   |                  |
|          | address needs    |                   |                  |
|          | for corrections  |                   |                  |
|          | or other         |                   |                  |
|          | adjustments.     |                   |                  |
+----------+------------------+-------------------+------------------+
| **Verifi | Sel              | *For reporting    | Designated       |
| cation** | f-certification; | purposes*, no     | agency to        |
|          | third-party      | change required.  | verify. Entity   |
| **Prov   | verification     | *For both         | may verify       |
| isions** | optional. No     | baseline          | through third    |
|          | federal agency   | protection and    | party.           |
|          | certification.   | transferable      |                  |
|          |                  | credit*, some     |                  |
|          |                  | form of external  |                  |
|          |                  | verification or   |                  |
|          |                  | certification may |                  |
|          |                  | be needed.        |                  |
+----------+------------------+-------------------+------------------+
| **Co     | Subject to       | No change         | \$25,000/day     |
| mpliance | criminal         | required.         | civil penalty    |
| Prov     | sentence or fine |                   | for              |
| isions** | for filing of    |                   | noncompliance    |
|          | false reports.   |                   | with mandatory   |
|          |                  |                   | reporting        |
|          |                  |                   | provisions.      |
+----------+------------------+-------------------+------------------+
| **Avai   | Under            | DOE regulations   | Information in   |
| lability | 1605(b)(3),      | should expressly  | data base must   |
| of       | trade secret and | allow             | be published     |
| Inform   | commercial or    | participants to   | except where     |
| ation/** | financial        | withhold          | designated       |
|          | information that | confidential      | agency           |
| **C      | is privileged or | business          | determines that  |
| onfident | confidential is  | information under | publishing the   |
| iality** | protected under  | 5 U.S.C. section  | information      |
|          | 5 U.S.C. section | 552(b)(4) or      | would disclose   |
|          | 552(b)(4).       | other federal     | information      |
|          | However, DOE     | law.              | vital to         |
|          | regulations      |                   | national         |
|          | appear to limit  |                   | security.        |
|          | that protection. |                   |                  |
+----------+------------------+-------------------+------------------+