Domain: Energy
Question:
You're advising an internal ESG analytics team that wants to treat facility-level GHGRP data (≈2011-2023) as the primary "system of record" for three forward-looking workflows: (i) building a baseline and projecting future emissions trends, (ii) setting and justifying multi-year reduction targets, and (iii) tracking progress and attributing year-over-year changes to "performance" versus "noise." Given that the GHGRP time series can have missing years and inconsistent coverage by facility, includes little to no operational or business-activity context to explain changes (e.g., expansions/closures/output shifts), and is largely limited to direct (Scope 1) emissions rather than a complete inventory, identify the key failure modes this creates for each of the three workflows above. For each failure mode, explain why it is structurally likely under GHGRP's design/purpose (i.e., a program oriented toward monitoring historical direct emissions for policy/program insights) and how it could materially bias or undermine any future-facing conclusions the company might draw.

Expected points in a correct answer:
States that the GHGRP encourages transparency and improvements over time.
States that the EPA's Greenhouse Gas Reporting Program (GHGRP) requires reporting of GHG data from large emissions sources and suppliers in the United States.
States that the purpose of the GHGRP is to provide nationwide data on an annual basis to inform policies and programs.
States that GHGRP data is not always consistently available for every facility for every given year between 2011–2023.
States that gaps in GHGRP data exist for reasons such as data not provided in time, emissions below EPA thresholds, or changes in business operations.
States that historical gaps in the data may make it difficult to accurately forecast future emissions by creating unreliable baselines for trend projection.
States that historical data is not always indicative of future performance due to changes in business operations such as expansion or closure of a facility.
States that the GHGRP does not provide insight into business activity context such as output or productivity.
States that without operational context such as output or productivity data, it is difficult to explain why GHG emissions changed from year to year
States that without operational context, it is difficult to distinguish between emissions changes driven by real performance versus structural noise
Identifies specific types of structural changes, such as facility expansions, closures, or output shifts, as examples of noise that could be incorrectly attributed to operational performance
States that the GHGRP is primarily focused on direct emissions, commonly known as Scope 1 emissions.
States that Scope 1 emissions are typically the easiest for the emitter to influence as they reside within the emitter's direct control.
States that per the Greenhouse Gas Protocol, indirect emissions such as Scope 2 and Scope 3 should also be accounted for to ensure a complete GHG inventory.
States that Scope 2 and Scope 3 emissions are not included in the GHGRP.
States that the lack of Scope 2 and Scope 3 data limits the usefulness of GHGRP for forecasting and target setting requiring a full GHG inventory.
Explains that GHGRP is oriented toward monitoring historical direct emissions for policy/program insights, not forward-looking analysis.
States that the GHGRP data may not be suitable for forward-looking purposes due to the identified limitations.
States that the GHGRP provides data at the facility level.
States that the GHGRP monitors emissions in aggregate (not just facility-level) to inform policy-making.
States that Scope 2 and Scope 3 emissions should be reported "where relevant" per the Greenhouse Gas Protocol.