Why are both downstream and upstream reporting required?
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 e
