Design issues in a mandatory greenhouse gas emissions registry for the United States

On March 10, 2009, the US Environmental Protection Agency (EPA) proposed a new rule, Mandatory Reporting of Greenhouse Gases. When final, the rule would compel most large sources of greenhouse gases (GHGs) to report their emissions to EPA as well as fossil fuel suppliers and vehicle engine manufacturers to report their fuel sales and engine emissions rates, respectively. We suggest a number of improvements to the rule that would enhance compatibility with expected future climate legislation and enable a broader range of policies and analysis: (1) lower the threshold for reporting to a level more consistent with expected future legislation, (2) require reporting of electricity use along with direct emissions, (3) require reporting of emissions per unit output for a small number of selected sectors, (4) include a system of identifying corporate ownership of reporting facilities, and (5) identify a path toward coverage for sectors that were left out of the proposal due to underdeveloped reporting protocols.