Domain: Energy
Question:
A U.S.-based parent company is rolling up facility-level emissions data from EPA's Greenhouse Gas Reporting Program (GHGRP) across multiple subsidiaries to support an "integrated sustainability and climate strategy," including: (a) forecasting its emissions trajectory, (b) setting enterprise-wide emissions-reduction targets that can withstand external scrutiny, and (c) pursuing Science-Based Targets initiative (SBTi) validation. Leadership argues that GHGRP is a mandatory, nationwide dataset with standardized reporting and therefore should be "complete enough" to serve as the company's system of record for target-setting. Using only the information implied by GHGRP's design and boundaries (facility reporting thresholds and emissions scopes), evaluate whether the company can use its GHGRP dataset as a standalone foundation to develop and validate SBTi-aligned targets. In your assessment, explicitly address: 1) Boundary integrity: whether GHGRP's emissions boundary aligns with the Greenhouse Gas Protocol boundary required for a complete corporate inventory used in science-based target validation (including what is missing and why it matters). 2) Coverage completeness: how GHGRP's reporting threshold (e.g., facilities below the threshold) can create systematic gaps in the company's "company-wide" Scope 1 baseline--even if the dataset appears extensive. 3) Decision consequence: what specific kinds of target-setting errors or credibility risks could occur if leadership treats GHGRP regulatory completeness as equivalent to SBTi inventory completeness. 4) Remediation path (high level): what additional emissions data categories and/or boundary expansions the company would need to integrate (beyond GHGRP) to make its dataset suitable for SBTi-aligned target setting--without assuming GHGRP can be "fixed" to include those elements.

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 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 per the Science-Based Targets initiative (SBTi), entities must include all three scopes of emissions in their targets to receive validation.
States that since Scope 2 and Scope 3 are not in the GHGRP, the company will need other data sources to set science-based targets.
States that the GHGRP only requires reporting for facilities that emit more than 25,000 mtCO2e.
States that lower-emitting facilities within the company's control may not be included in the GHGRP dataset.
States that GHGRP data cannot be used to set science-based targets on a standalone basis.
States that the GHGRP does not contain complete company-wide Scope 1 emissions (due to the reporting threshold).
States that the data for lower-emitting facilities (below the GHGRP threshold) will need to come from another source, limiting the usefulness of GHGRP data for target-setting on a standalone basis.
States that the GHGRP's primary purpose is to monitor total historical direct emissions at the facility level and in aggregate to inform policy-making.