Q33. Will there be double-reporting of emissions under this rule?
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.

Yes. There is inherent double-reporting of emissions in a program that includes both upstream and downstream sources. For the reasons discussed above, collecting greenhouse gas (GHG) emissions from both upstream production and downstream sources is consistent with the request from Congress and provides valuable information to EPA and stakeholders in the development of climate change policy and programs. That said, EPA does not intend to use emissions data collected by this rule as a replacement for the national emission estimates found in the annual Inventory of U.S. GHG Emissions and Sinks. That Inventory is a comprehensive, top-down national assessment of U.S. GHG emissions, and it uses top-down national energy data and other national statistics. Whereas this rule, collects GHG emissions data from certain sources over a specific threshold and the data collected will serve as a useful tool to better improve the accuracy of future national-level inventories.

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