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FAQs
Reporting Concepts/ Entity Definitions
See Who Can Report?
- How should I define my entity?
DOE strongly encourages you to define your entity at the highest level of aggregation, although reporting at some lower level is permitted.
Once you define that level of corporate or institutional management at which you will report (e.g., the holding company, subsidiary, regulated stationary source, state government, agency, etc.), you must include all elements of the organization encompassed by that management level and exclude any organizations that are managed separately. For example, if you include two subsidiaries of your parent company in a single report, then all subsidiaries of your parent company must also be included.
Instructions for Form EIA-1605, pp.3
General Guidelines, §300.3
- How should I name my entity?
The name given to your entity should closely correspond to the scope of the operations and emissions covered in your report. If you intend to register reductions, choose a name commonly used to represent the activities included in the entity. The name should not also be used to refer to activities outside of your entity definition. When reporting an individual plant or operating unit of a corporation or subsidiary as an entity, use a name that corresponds to the specific plant or unit, and not to the responsible corporate or subsidiary entity.
Instructions for Form EIA-1605, pp.3
General Guidelines, §300.3
- What are organizational boundaries?
An entity's organizational boundaries are the actual or virtual lines that encompass all emissions and carbon stocks to be quantified and reported in an entity's greenhouse gas inventory, including de minimis emissions. In other words, you entity's organizational boundaries determine the scope of your report and the emissions sources that are the responsibility of your entity.
General Guidelines, §300.4
- Which methods can be used to determine the boundaries of an entity?
Financial control is the perferred approach for determining the organizational boundaries of an entity and which emissions sources the entity will include in its emissions inventory. Entities may also use the equity share or operational control approaches to establish their organizational boundaries.
General Guidelines, §300.4
- What is financial control?
Financial control is the recommended approach under the 1605(b) Program for determining an entity's boundaries. Financial control refers to an entity's ability to direct the financial policies of all elements of that entity with a view to gain economic benefit from its activities over a period of many years. This approach should ensure that all sources, including those controlled by subsidiaries, that are wholly or largely owned by the entity are covered by its reports.
Sources that are under long-term lease of the entity may, depending on the provisions of such leases, also be considered to be under the entity's financial control. Financial control would exist if the entity has a long-term lease or long-term agreement that gives it effective control over capital investment and operational decisions (e.g., a finance or capital lease). Sources that are temporarily leased or operated by an entity generally would not be considered to be under its financial control.
General Guidelines, §300.4(a)(1)
- What is operational control?
Operational control is an alternative approach for determining an entity's boundaries and refers to an entity's ability to direct the operational policies of all elements of that entity. For example, when an entity controls the day-to-day operations of a facility or source, but does not own the facility or source, operational control exists.
Emissions reductions or sequestration associated with sources not owned or leased by the entity may not be included in the entity's reports under the program unless the entity has long-term control over the emissions or sequestration of the source and the owner of the source has agreed that the emissions or sequestration may be included in the entity's report. Operation control would allow an entity that leases office space under an operating lease to report the emissions associated with those operations, as long as they assume responsibility for all operational decisions for the facility or source during the term of the lease. The entity does not have financial interest in the source, but nevertheless can report the emissions, as they control the day-to-day operations of the source.
Note: If the operational control approach is used to determine an entity's boundaries, the reporting entity must inform the other entities that share responsibility for particular sources of its intention to report under the 1605(b) Program. This communication ensures that source emissions or reductions are not double reported under the program.
Equity share implies the percentage interest in ownership, benefits, or control that may govern entitlements to emission reductions by participants in collective undertakings. Under the 1605(b) Program, equity share is an alternative approach to determining entity boundaries. Equity share exists when more than one entity has a financial interest in a particular facility or emission source, and each of the entities take responsibility for reporting only a portion of the facilities emissions or reductions.
Note: If the equity share is used to determine an entity's boundaries, the reporting entity must inform the other entities that share responsibility for particular sources of its intention to report under the 1605(b) Program. This communication ensures that source emissions or reductions are not double reported under the Program.
General Guidelines, §300.4
Technical Guidelines, Glossary
- How are my emissions from a rented facility reported?
Emissions from a rented facility are reported in one of two ways, depending on the lease agreement.
Financial Control: Facilities or sources that are under a long-term lease agreement may be considered under the financial control of the lease, and thus may be reported as direct emissions by the renting entity. An applicable long-term lease agreement would grant the lesee effective control over capital investment and operational decisions.
Operational Control: The existence of an operating lease would allow the lessee to report emissions from the source, if they control the day-to-day operations of the source. The reporting entity would have to meet the provisions in §300.4(a)(3) of the General Guidelines; in other words, it would need to establish that it has long-term control over the source and that the owner of the source has agreed to the reporting of these emissions/reductions.
In either of the cases above, leased facilities can only be reported to the Program if an agreement exists between the lessee and lessor of the source, and reasonable steps have been taken to ensure that the source is not double reported to the 1605(b) Program.
General Guidelines, §300.4
- My entity has financial control over the forests that it owns, but it relies on contractor companies to conduct operations. How would I report these contractor operations?
If your entity has long-term financial control over the emissions or sequestration of the source, and if your contract is deemed a long-term relationship, you may report the emissions from contract operations. Your entity must take responsibly steps (such as telephone, fax, letter, or e-mail communications) to ensure that direct emissions, emission reductions, and/or sequestration reported to the Program are not double reported by the other entity.
General Guidelines, §300.4(a)(1), §300.4(3), §300.10(c)(1)
- Can an organization omit a business unit from its emissions inventory?
An organization may omit a business unit from its inventory only if it intends to report but not register reductions and the selected elements, sources, or gases that the entity chooses to report do not encompass any operations of the omitted business unit. Entities may not "cherry pick" their more "favorable" business units, but must maintain entity and activity boundaries and definitions in keeping with the guidelines. Large emitters that intend to register reductions must include all elements of an entity in an emissions inventory, as determined by its organizational boundaries.
General Guidelines, §300.3(b)
- Can I register a single building in our corporation to the 1605(b) Program?
You can register a single building in your corporation to the 1605(b) Program only if the respective building has its own separate incorporation towards your organization. You can only report a single building if you can define your entity as a single-building entity using the guidelines in §300.3(a) of the General Guidelines. However, it must be noted that EIA encourages you to define your entity at the highest level of aggregation.
General Guidelines, §300.2
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