Q32. Why are both downstream and upstream reporting required?
Note: The Cal e-GGRT help system includes general instruction on using the California GHG reporting tool. However, the help system may not explain differences between California and U.S. EPA reporting requirements. Please refer to the ARB reporting website for California-specific reporting requirements and additional help.

This rule responds to a specific request from Congress to collect data on greenhouse gas (GHG) emissions from both upstream production and downstream sources, as appropriate. The rule requires reporting by facilities that directly emit GHGs above the selected threshold as a result of combustion of fuel or industrial processes (downstream sources). The majority of these reporters are large facilities in the electricity generation and industrial sectors. The rule also requires upstream suppliers of fossil fuels and industrial GHGs to report the GHG emissions that could be emitted from combustion or use of the quantity of fuels or industrial gases supplied into the economy. In many cases, the fossil fuels and industrial GHGs supplied by producers and importers are used and ultimately emitted by a large number of small sources. To cover these direct emissions would require reporting by hundreds or thousands of small facilities. To avoid this impact, the rule does not include all of those emitters but instead requires reporting by the suppliers of industrial gases and suppliers of fossil fuels. The data collected under this rule are consistent with the appropriations language and provide valuable information to EPA and stakeholders in the development of climate change policy and programs. Potential policies such as low carbon fuel standards can only be applied upstream, whereas end-use emission standards can only be applied downstream. Data from upstream and downstream sources would be necessary to formulate and assess the impacts of such potential policies. Eliminating reporting by either upstream sources or downstream sources would not satisfy EPA's data needs and policy objectives of this rule.

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