Part A-ssEnhanced1605b-year2006-Final

U.S. Department of Energy
Energy Information Administration

Supporting Statement

Voluntary Reporting of Greenhouse Gases Program Survey:
Form EIA-1605
OMB Number: 1905-0194

November 9, 2006

Table of Contents
BACKGROUND ..........................................................................................................................................................1
CURRENT VOLUNTARY REPORTING OF GREENHOUSE GASES PROGRAM .............................................................1
ENHANCED VOLUNTARY REPORTING OF GREENHOUSE GASES PROGRAM UNDER PRESIDENT’S CLIMATE
CHANGE INITIATIVE ................................................................................................................................................1
A. JUSTIFICATION ..................................................................................................................................................5
A-1. STATUTORY AUTHORITY ................................................................................................................................5
A-2. DATA NEEDS AND USES ....................................................................................................................................6
A-3. TECHNOLOGICAL CONSIDERATIONS ...............................................................................................................8
A-4. EFFORTS TO IDENTIFY DUPLICATION AND ANALYSIS OF SIMILAR EXISTING INFORMATION.......................9
A-5. PROVISION FOR REDUCING BURDEN ON SMALL BUSINESS ..........................................................................11
A-6. CONSEQUENCES OF LESS FREQUENT REPORTING .......................................................................................11
A-7. COMPLIANCE WITH 5 CFR 1320.5................................................................................................................12
A-8. SUMMARY OF COMMENTS ON THE FEDERAL REGISTER NOTICE CONTAINING THE REQUEST FOR:1) A 3YEAR EXTENSION OF THE FORMS EIA-1605 AND EIA-1605EZ; AND 2) MODIFICATIONS TO THE FORM EIA1605 (LONG VERSION). ...........................................................................................................................................12
A-9. REMUNERATION ............................................................................................................................................20
A-10. PROVISIONS OF CONFIDENTIALITY OF DATA .............................................................................................20
A-11. JUSTIFICATION FOR QUESTIONS OF A SENSITIVE NATURE ........................................................................20
A-12A. ESTIMATES OF REPORTING BURDEN ........................................................................................................21
A-12B. ANNUALIZED COST TO THE RESPONDENTS ..............................................................................................21
A-13. TOTAL ANNUAL COST BURDEN ..................................................................................................................21
A-14. TOTAL ANNUAL COST TO THE FEDERAL GOVERNMENT ...........................................................................21
A-15. PROGRAM CHANGES OR ADJUSTMENTS .....................................................................................................22
A-16. PUBLICATION AND TABULATION SCHEDULE FOR THE YEAR 2001 REPORTING CYCLE UNDER EXISTING
DATA COLLECTION ................................................................................................................................................23
A-17. EXPIRATION DATE.......................................................................................................................................23
A-18. CERTIFICATION STATEMENT .......................................................................................................................23
B. DESCRIPTION OF DATA COLLECTION AND SURVEY DESIGN ...........................................................23
B-1.
B-2.
B-3.
B-4.

COLLECTION OF DATA ..................................................................................................................................23
DESCRIPTION OF SURVEY DESIGN ................................................................................................................24
MAXIMIZING THE RESPONSE RATE ..............................................................................................................24
TESTS OF PROCEDURES OR METHODS ..........................................................................................................24

C. TERMS OF CLEARANCE FROM PREVIOUS INFORMATION COLLECTION REQUEST.................24
D. NAME AND TELEPHONE NUMBER OF PROGRAM CONTACT PERSON ...........................................25
E. ENCLOSURE.......................................................................................................................................................25

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Background

Current Voluntary Reporting of Greenhouse Gases Program
The Energy Information Administration’s (EIA) Voluntary Reporting of Greenhouse Gases
Program collections are conducted pursuant to Section 1605(b) of the Energy Policy Act of 1992
(Pub. L. 102-486, 42 U.S.C. 13385) under General Guidelines issued by the Department of
Energy’s (DOE) Office of Policy and International Affairs. The EIA-1605 and EIA-1605EZ
forms were designed to collect voluntarily reported data on greenhouse gas emissions, achieved
reductions of these emissions, and increased carbon fixation, as well as information on
commitments to reduce greenhouse gas emissions and sequester carbon in future years. A
summary of the results of the Voluntary Reporting of Greenhouse Gases Program appear in the
Program’s annual report titled Voluntary Reporting of Greenhouse Gases
(http://www.eia.doe.gov/oiaf/1605/vrrpt/). Additionally, EIA produces and makes publicly available, a
“public-use” database containing all the non-confidential information reported to EIA’s
Voluntary Reporting of Greenhouse Gases Program on the Forms EIA-1605 and EIA-1605EZ
(http://www.eia.doe.gov/oiaf/1605/databases.html).
The EIA, as part of its effort to comply with the Paperwork Reduction Act of 1995 (Pub. L. 10413, 44 U.S.C. Chapter 35), provides the general public and other Federal agencies with
opportunities to comment on collections of information conducted by or in conjunction with the
EIA. Any comments received help the EIA to prepare data requests that maximize the utility of
the information collected and to assess the impact of collection requirements on the public. The
EIA later seeks approval by the Office of Management and Budget (OMB) under Section
3507(a) of the Paperwork Reduction Act of 1995.
The “terms of clearance” for the previous approval are addressed on page 26 of this
document.
Enhanced Voluntary Reporting of Greenhouse Gases Program under President’s Climate
Change Initiative
On February 14, 2002, President Bush announced the Climate Change Initiative (CCI). The CCI
includes a series of programs and initiatives to address the issue of global climate change,
including a greenhouse gas intensity reduction goal, energy technology research programs,
targeted tax incentives to advance the development and adoption of new technologies, and
voluntary programs to promote actions to reduce greenhouse gases. As part of the CCI, the
President directed the Secretary of Energy, in consultation with the Secretary of Commerce, the
Secretary of Agriculture, and the Administrator of the Environmental Protection Agency, to
propose improvements to the current Voluntary Reporting of Greenhouse Gases Program
required under section 1605(b) of the Energy Policy Act of 1992. These improvements are to
enhance measurement accuracy, reliability, and verifiability, working with and taking into
account emerging domestic and international approaches. The President also directed the
Secretary of Energy to recommend reforms to ensure that businesses and individuals that register
reductions are not penalized under a future climate policy and to give transferable credits to

companies that can show real emissions reductions.
The purposes of the proposed Program enhancements are to: (1) establish revised procedures and
reporting requirements for filing voluntary reports, and (2) encourage corporations, government
agencies, non-profit organizations, individuals and other private and public entities to submit
annual reports of their total entity-wide greenhouse gas emissions, net emission reductions, and
carbon sequestration activities that are complete, reliable and consistent.
On May 6, 2002 (67 FR 30370), the Department of Energy solicited public comments on various
issues relevant to its efforts to implement the President’s directives. After consideration of these
public comments, the Secretaries of Energy, Commerce and Agriculture, and the Administrator
of the Environmental Protection Agency wrote the President on July 8, 2002, stating that
improvements to the existing Voluntary Greenhouse Gas Reporting Program should:
1. Develop fair, objective, and practical methods for reporting baselines, reporting
boundaries, calculating real results, and awarding transferable credits for actions that lead
to real reductions.
2. Standardize widely accepted, transparent accounting methods.
3. Support independent verification registry reports.
4. Encourage reporters to report greenhouse gas intensity (emissions per unit of output) as
well as emissions reductions.
5. Encourage corporate or entity-wide reporting.
6. Provide credits for actions to remove carbon dioxide from the atmosphere as well as for
actions to reduce emissions.
7. Develop a process for evaluating the extent to which past reductions may qualify for
credits.
8. Assure the voluntary reporting program is an effective tool for reaching the President’s
Climate Change Initiative goal of reducing U.S. greenhouse gas intensity (greenhouse
gas emissions per unit of gross domestic product) by 18 percent over the 2002 to 2012
time frame.
9. Factor in international strategies as well as State-level efforts.
10. Minimize transactions costs for reporters and administrative costs for the Government,
where possible, without compromising the foregoing recommendations.
The DOE also held four public workshops (67 FR 64106) in the fall of 2002 to enable interested
persons to discuss and provide comments on possible improvements to the Program guidelines.
Public comments submitted to DOE’s Office of Policy and International Affairs on possible
revisions to the Voluntary Reporting of Greenhouse Gases Program General and Technical
Guidelines are available at http://www.pi.energy.gov/enhancingGHGregistry/index.html.
On November 26, 2003, DOE released proposed revised General Guidelines for the Voluntary
Reporting of Greenhouse Gases Program. On January 12, 2004, DOE held a public
workshop to discuss the proposed, revised General Guidelines and to receive comments from
the public.
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On March 24, 2005, DOE issued the Interim Final General Guidelines (70 FR 15169) and a
“Notice of Availability” for the Draft Technical Guidelines (70 FR 15164) with a 60-day
comment period. Both DOE and the U.S. Department of Agriculture (USDA) held workshops
to solicit comments on the Interim Final General Guidelines and the Draft Technical
Guidelines. The DOE workshop, held on April 26-27, 2005, in Arlington, Virginia, was
attended by more than 150 individuals. The USDA workshop was held on May 5, 2005, in
Riverdale, Maryland, to address technical and methodological issues associated with
preparing estimates of greenhouse gas emissions and carbon sequestration from agriculture
and forestry activities.
On April 21, 2006, 1 DOE issued final General and Technical Guidelines for the revised
Voluntary Reporting of Greenhouse Gases Program (71 FR 20784)
(http://www.eia.doe.gov/oiaf/1605/Gen%20Guidelines%20final%20rule%20Apr21.pdf). The new Program
guidelines became effective on June 1, 2006.
In response to the issuance and finalization of the revised General and Technical Guidelines,
EIA, on July 27, 2006, issued for review and public comment (71 FR 42637) revised reporting
forms and instructions for reporting under the revised Program Guidelines. The first year of
reporting to the Program under the revised Guidelines is expected to occur in the late summer of
2007, for 2006 data.
EIA is requesting OMB approval for a 3-year extension of the Form EIA-1605, with revisions;
and for the discontinuation of Form EIA-1605EZ (short form). The revisions to Form EIA-1605
are summarized below.
Schedule I: On the existing Schedule I, “Entity Identification and Certification,” the focus was
limited to asking for information to identify the reporting entity, the type of reporting entity, the
geographic scope of activities, the Standard Industrial Classification Code (SIC), the
applicability of confidentiality, and the reporting entities attesting to/certifying the accuracy of
the information reported. The revised Schedule I, “Entity Information,” has been expanded to
include an inventory of emissions and emissions reductions, carbon flux, and emissions offsets,
all calculated at the entity level. In addition, Schedule I includes the collection of NAICS codes
(instead of SIC codes), an expanded list of entity type categories, information on any changes in
entity information from previous reporting years, and other reporter characteristics, such as base
period, voluntary program affiliation, and entity organization.
Schedule II: On the existing Schedule II, “Project-level Emissions and Reductions,” the
reporting entity was asked to provide information on individual projects that had achieved
reductions in greenhouse gas emissions and/or have sequestered carbon. The revised Schedule
II, “Subentity Information,” collects data that are similar to data collected on Schedule I of the
revised Form EIA-1605, but on a subentity-level basis. The Program guidelines define a
1 U.S. Department of Energy, Guidelines for Voluntary Greenhouse Gas Reporting; Final Rule, 71 Federal Register
20784, April 21, 2006, http://www.pi.energy.gov/pdf/library/April21FRwithFinalGG.pdf.

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subentity as a component of any entity, such as a discrete business line, facility, plant, vehicle
fleet, or energy using system, which has associated with it emissions of greenhouse gases that
can be distinguished from the emissions of all other components of the same entity and, when
summed with the emissions of all other subentities, equal the entity’s total emissions. Projectlevel or action-specific reductions can be registered under limited circumstances using the
calculation methods specified in the Technical Guidelines and embodied in Addendum A of the
revised form.
Schedule III: On the existing Schedule III, “Entity-level Emissions and Reductions,” the
reporting entity was able to establish a record of its greenhouse gas emissions, emissions
reductions and carbon sequestration achievements. Schedule III was used to report information
such as actual emissions for the baseline period (as early as 1987 to 1990), emissions for
subsequent years (1991 to the present), emission reductions for the years 1991 to the present, and
causes for changes in the levels of emissions and/or emissions reductions, all at the entity-level.
The collection of entity-level emissions and reductions has been incorporated into Schedule I in
the revised form. The revised Schedule III, “Emissions Reductions Summary,” focuses on
summarizing the entity-level emissions reductions, based on information reported by the entity
on Schedule I or Schedule II. Reporters may subdivide the entity into two or more subentities to
permit the use of different calculation methods for estimating reductions.
Schedule IV: On the existing Schedule IV, “Commitments to Reduce Greenhouse Gases,” the
Reporting entity was provided the opportunity to report on its commitments made, under a
variety of governmental initiatives, to reduce greenhouse gases. The information gathered
included descriptions of the commitment, the type of reference case used to calculate emissions
reductions, the voluntary program the reduction activity was affiliated with (if applicable), as
well as information on financial commitments made to support activities designed to reduce
greenhouse gas emissions. Collection of commitment information has been discontinued in the
revised form.
The revised Schedule IV, “Verification and Certification,” provides an opportunity for reporters
to document optional independent, “third-party” verification of the information reported on the
Form EIA-1605 and expands the certification statement that all reporters must sign. Third-party
verification was not included on the existing EIA-1605 form. Schedule IV of the revised form
consists of two sections. The first section titled, “Independent Verification,” collects
information on the identity and qualifications of the independent verifier and verification
approach and includes the independent verifier’s certification. The second section titled
“Reporter Self-Certification,” is a required self-certification, including the reporter’s declaration
that the form meets all three requirements for “reported” reductions 2 , and in the case of
“registered” reductions3, five additional requirements.
2 “Reported” reductions can be compiled at any level (project, facility, etc.), do not require an entity-wide emission
inventory, do not require reporters to meet the 3.0 minimum data quality rating, and can be reported for years 1991
and later.
3 “Registered” reductions require that entity compile an entity-wide emission inventory, meet minimum data
quality standards of 3.0 or higher, calculate emission reductions across the entire entity, and can only be registered

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Addendum: The form includes the following addenda for portions of the form that will not be
required for all reporters: Addendum A, Emission Reduction Methods; Addendum B, Subentity
Emissions Inventory; and Addendum C, Country-specific Factors Used to Estimate Emissions
from Foreign Sources. Addendum A includes sixteen (A1-A16) different emission reduction
methods to be used by reporters to calculate and submit emission reductions. Addendum B is to
be used by reporters that are subdividing their entity into subentities and allows those reporters
to submit subentity-specific emission inventories. Addendum C is to be used by reporters
submitting data on foreign activities and allows those reporters to report those emission factors
used to calculate foreign emissions and reductions.
The information collection proposed in this supporting statement has been reviewed in light of
applicable information quality guidelines. It has been determined that the information will be
collected, maintained, and used in a manner consistent with the Office of Management and
Budget (OMB), DOE, and EIA information quality guidelines.

A. Justification
A-1. Statutory Authority
The statutory authority of this voluntary program is section 1605(b) of the Energy Policy Act of
1992 (Public Law 102-486, 42 USC 13385) that states:
(b) Voluntary Reporting. (1) Issuance of Guidelines. - Not later than 18 months after the date of the
enactment of this Act, the Secretary shall, after opportunity for public comment,
issue guidelines for the voluntary collection and reporting of information on
sources of greenhouse gases. Such guidelines shall establish procedures for the
accurate voluntary reporting of information on(A) greenhouse gas emissions(i) for the baseline period of 1987 through 1990; and
(ii) for subsequent calendar years on an annual basis;
(B) annual reductions of greenhouse gas emissions and carbon fixation
achieved through any measures, including fuel switching, forest
management practices, tree planting, use of renewable energy,
manufacture or use of vehicles with reduced greenhouse gas emissions,
appliance efficiency, energy efficiency, methane recovery, cogeneration,

for years 2003 and beyond. Minor exceptions to these requirements allow small emitters to register reductions for
selected activities, and selected participants in DOE’s Climate VISION Program and EPA’s Climate Leaders
Program to register reductions as early as 2001 and beyond.

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chlorofluorocarbon capture and replacement, and power plant heat rate
improvement;
(C) reductions in greenhouse gas emissions achieved as a result of (i) voluntary reductions;
(ii) plant or facility closings; and
(iii) State or Federal requirements; and
(D) an aggregate calculation of greenhouse gas emissions by each
reporting entity.
Such guidelines shall also establish procedures for taking into account the differential
radiative activity and atmospheric lifetimes of each greenhouse gas.
(2) REPORTING PROCEDURES. - The Administrator of the Energy Information
Administration shall develop forms for voluntary reporting under the guidelines
established under paragraph (1), and shall make such forms available to entities
wishing to report such information. Persons reporting under this subsection shall
certify the accuracy of information reported.
(3) CONFIDENTIALITY. - Trade secret and commercial or financial information
that is privileged or confidential shall be protected as provided in section 522
(b)(4) of Title 5, United States Code.
(4) ESTABLISHMENT OF DATA BASE. - Not later than 18 months after the
date of enactment of this Act, the Secretary, through the Administrator of the
Energy Information Administration, shall establish a data base comprised of
information voluntarily reported under this subsection. Such information may be
used by the reporting entity to demonstrate achieved reductions of greenhouse
gases.
The EIA-1605 and EIA-1605-EZ reporting forms were formulated pursuant to the program
guidelines developed by the DOE’s Office of Policy and International Affairs. DOE finalized
the Program Guidelines in 1994 following a public comment period and public hearing on a set
of the proposed guidelines. The availability of the Program Guidelines was announced in the
Federal Register on October 19, 1994 (59 FR 52769). These Guidelines are entitled Voluntary
Reporting of Greenhouse Gases under Section 1605(b) of the Energy Policy Act of 1992 General Guidelines and Supporting Documents (DOE/PO-0028), October 1994 (available at
http://www.eia.doe.gov/oiaf/1605/guidelns.html). As mentioned above, however, the original
guidelines have now been superseded by revised General and Technical Guidelines issued by
DOE on April 21, 2006, 4 which became effective on June 1, 2006.
A-2. Data Needs and Uses
The EIA prepares an annual report summarizing the results of the Program, based on the
information reported on the Forms EIA-1605 and EIA-1605EZ, titled Voluntary Reporting of
Greenhouse Gases [DOE/EIA-0608]. This report highlights and recognizes reporters’ efforts to
4 U.S. Department of Energy, Guidelines for Voluntary Greenhouse Gas Reporting; Final Rule, 71 Federal Register
20784, April 21, 2006, http://www.pi.energy.gov/pdf/library/April21FRwithFinalGG.pdf.

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reduce or avoid greenhouse gas emissions at both the project- and entity-levels. The most recent
report issued is Voluntary Reporting of Greenhouse Gases 2004, released in March 2006. This
report can be accessed directly at http://www.eia.doe.gov/oiaf/1605/vrrpt/. With the
discontinuation of Form-1605EZ, this report will focus on emissions and reductions reported on
the revised Form EIA-1605.
The EIA also established and maintains, pursuant to requirements under Section 1605(b) of the
Energy Policy Act of 1992, a public-use database containing the data/information reported to the
Program. This database, which serves as a clearinghouse of information and case studies on
greenhouse gas reduction and carbon sequestration activities, is updated annually and is made
available to the public on the Program’s CD-ROM and is downloadable via the Internet from the
EIA’s website (http://www.eia.doe.gov/oiaf/1605/databases.html).
The original Voluntary Reporting of Greenhouse Gases Program was unique among the existing
voluntary emission reduction programs in its diversity of project types, participation, and
approaches. The Voluntary Reporting of Greenhouse Gases Program's database provides a
wealth of examples of the types of concrete actions that organizations can undertake to reduce
greenhouse gas emissions. Some of the most important uses/benefits of the Voluntary Reporting
Program include:
•

Education - The program helps educate staff at many of the largest corporations in the
United States how to estimate their greenhouse gas emissions, and educates them on a
range of possible measures to limit their emissions. This is an important requirement for
future action to reduce emissions.

•

Information - Reporters can learn about innovative emission reduction activities from
the experiences of their peers. This potential has been illustrated for gases with strong
heat trapping capacities. In the first reporting cycle, 9 companies reported 14 projects that
reduced emissions of methane from municipal solid waste landfills via the recovery
landfill gas, which was is in turn either flared or used for energy. These projects reduced
indirect methane emissions by 2.3 million metric tons carbon dioxide equivalent. As
more reporters realized that avoiding emissions of one ton of methane, with its higher
heat trapping capacity, holds the same benefit as reducing 23 tons of carbon dioxide
emissions, reporting on these projects has increased. For the 2004 data reporting cycle,
for example, 56 entities reported 392 landfill gas recovery projects that reduced direct
methane emissions by 48.8 million metric tons carbon dioxide equivalent and indirect
methane emissions by 18.6 million metric tons carbon dioxide equivalent.

•

Voluntary Reporting Mechanism - The program has served as a reporting mechanism
for a number of government voluntary programs, including the Department of Energy’s
(DOE) Climate Challenge Program, Environmental Protection Agency’s (EPA) Landfill
Methane Outreach Program, the U.S. Initiative on Joint Implementation, and the Energy
Star Program (a joint program of DOE and EPA).

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•

Reported Emission Reductions Registry - The program has created a "test" database of
approaches to emission reductions that can be used to evaluate future emissions
limitation policy instruments. As such, the database serves as a registry of emissions and
reductions reported on the Forms EIA-1605 and EIA-1605EZ. The database preserves a
record for reporters demonstrating achieved reductions and sequestration as well as
emission levels. With this record, reporters may be able to establish a basis for future
policy or regulatory regimes.

•

Greenhouse Gas Accounting Issues - The program has illuminated many of the
important emissions accounting issues that must be addressed in designing any future
approaches to emission limitations.

The Voluntary Reporting Program was originally designed to be a general purpose registry and
reporting program for greenhouse gas emissions, reductions, and commitments. The original
design objectives of the EIA’s Voluntary Reporting of Greenhouse Gases Program, included:
•
•
•

Flexibility;
Broad participation; and
Allowance for the reporting of a broad range of greenhouse gas emissions reductions
activities/actions, without foreclosing or preempting future legal definitions of a
reduction, reporting entity, baselines, who can report, what can be reported, etc.

The focus of the revised Voluntary Reporting of Greenhouse Gases Program will follow the
President’s February 14, 2002 directive to “enhance the measurement accuracy, reliability, and
verifiability” of the Program. Key objectives of the new Program, according to DOE’s Office of
Policy and International Affairs will be to:
•

•
•

Encourage comprehensive, entity-wide reporting
o Of both emissions inventories and reductions
o Of all gases and sequestration
o Of direct and certain indirect emissions
Enhance quality, consistency and transparency
Use emissions intensity as the primary measure of reductions

With the key elements of the revised Program being:
•
•
•
•
•

Comprehensive emission inventory guidelines, with a quality rating system
Registration of qualifying reductions, including offsets
Entity-wide, emissions intensity focus
Broad recognition of avoided emissions and other special categories of reductions; and
Innovative guidance and tools for agricultural and forestry sectors.

A-3. Technological Considerations
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Pursuant to requirements under Section 1605(b) of the Energy Policy Act of 1992, the EIA
designed, developed, and implemented the Survey Forms EIA-1605 and EIA-1605EZ. As part
of the ongoing effort to reduce reporter burden, electronic versions of the forms were created to
facilitate electronic reporting of the data on Form EIA-1605 or Form EIA-1605EZ. The EIA
developed a “client-server” based database system, with ORACLE as the back-end database, as
well as a data entry sub-system for entering, editing, and browsing the data. This data entry subsystem has been distributed each year, to persons, firms, associations, and other types of
organizations, who voluntarily choose to participate and/or express an interest in participating in
the Program. This electronic version of the forms has helped to reduce respondent burden, ease
reporting, and facilitate filing. The previous versions of the forms and instructions were made
available on the Internet, as well as CD-ROM. The form EIA-1605-EZ also had an Internetbased reporting form that could be accessed at https://idc.eia.doe.gov/ghgez/Login.jsp. Before
using this option, reporters were required to contact EIA Greenhouse Gas Communications
Center to get a login name and password.
EIA is currently working on the development of Internet Data Collection (IDC) system for the
revised Form EIA-1605. The new IDC system will allow Program reporters to submit their
emissions and reductions data to EIA over the Internet. Reporters will access the IDC
application through EIA’s single sign-on application using specified user names and user IDs.
Reporters will be able to save and submit their data to the 1605b database. EIA currently
projects that this system will be operational around late-August, 2007. Reporters choosing not to
report via the IDC would still have the option of filling out a paper form and mailing or faxing it
to EIA.
A-4. Efforts to Identify Duplication and Analysis of Similar Existing Information
After a review of EIA’s other energy data survey collections forms, it was concluded that no
unnecessary duplication of reported data would be created. Furthermore, an analysis of similar
existing information was performed. This analysis also revealed no significant duplications in
reported material. A thorough investigation was made of current reporting practices of potential
reporters. This review divided the range of potential reporters into economic sectors: electricity
supply, industrial, residential and commercial buildings, transportation, agricultural, and
forestry.
(1) Electricity Supply Sector
For the electricity supply sector, existing data reported to EIA, Federal Energy Regulatory
Commission (FERC), and state regulatory authorities were investigated. Although a
considerable amount of energy-related data is currently reported to EIA and FERC, it is
primarily focused on estimating/calculating energy-use for specific sectors of the economy.
These other data collections are not normally used to estimate greenhouse gas emissions.

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Some emissions data are collected by the EPA under Title IV of the Clean Air Act Amendments
of 1990. Electric generators are required to monitor and report their emissions of acid rain
precursors, specifically, sulfur dioxide and nitrogen oxides, through continuous emissions
monitoring (CEM) systems. The flows of these gases are monitored frequently enough to
approximate continuous monitoring in order to report concentrations. While these data may
prove useful to reporting emissions under 1605(b), they do not address reporting greenhouse gas
emissions reductions. More importantly, these data are constrained to the definition of point of
source as a reporter or activity. The breadth of the 1605(b) program does not limit reporting to
individual point sources, but rather focuses on the emissions consequences of a broad-range of
activities.
(2) Industrial Sector
Both voluntary and mandatory reporting practices in the industrial sector were reviewed.
The set of mandatory reporting includes Securities and Exchange Commission (SEC) regulations
on financial information for the protection of investors. In addition, the annual reports of many
potential corporate reporters were investigated for non-financial operational data such as the
number of trees planted by a papermaking company. Again, the review illustrated that emissions
data were not generally reported although some of the existing data can be used by reporters as
inputs to estimating emissions or sequestration.
The Toxic Release Inventory (TRI) administered by the EPA primarily collects information on
emissions toxic to humans. Incorporated in this list are some ozone-depleting substances that,
under the General Guidelines, are reportable to the Voluntary Reporting Program. These data
are useful in determining some greenhouse gas emissions, but reductions information is not
reported. Thus, the TRI is a useful input, but does not constitute a complete report.
Operating information on production and other operating data collected by other government
agencies including the Departments of Commerce and Interior were investigated. This
information along with data reported to trade associations by constituent members was assessed.
None of this information specifically addresses emissions of the gases covered by this program.
However, it was determined that information reported will prove useful to those reporters who
wish to file the Form EIA-1605 by providing some input information for estimating their
greenhouse gas emissions and reductions.
(3) Commercial and Residential Sectors
Compared with electricity and industrial sectors, very little information on greenhouse gas
emissions is reported by the commercial and residential sectors. EIA collects data on the energy
usage of a representative sample of commercial buildings and households.
(4) Transportation Sector

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For transportation-related activities, items such as fuel use and vehicle miles traveled are
reported to various agencies including the Department of Transportation, the Department of
Commerce, and EIA. Such data are useful in calculating greenhouse gas information, though
this information is not sufficient for reporting an emission reduction.
(5) Agricultural and Forestry Sectors
Reviews of the agricultural and forestry sectors include data reported to the U.S. Department of
Agriculture (USDA). Information is also reported to the Federal tree planting programs that are
operated by USDA’s U.S. Forest Service. These programs are largely aimed at promoting
certain forestry practices such as forest management and reforestation after harvest, and are not
intended as data collection systems.
The effort to identify similar existing data sources yielded very useful findings for the form
design process because form design relies heavily on existing information from which reporters
can estimate emissions, reductions, and sequestration levels. Therefore, even though the existing
data sources are inadequate and not duplicative, the information plays a vital role in estimating
the effects of the activities undertaken to reduce greenhouse gas emissions and increase carbon
sequestration.
A-5. Provision for Reducing Burden on Small Business
Because the Form EIA-1605 is voluntary, no undue, unfair, or discriminatory burden is placed
on small businesses by this program. However, small businesses are encouraged to report all of
their efforts to reduce emissions. Small emitters, those with emissions of less than 10,000 metric
tons carbon dioxide equivalent and in many cases small businesses, are subject to lesser
reporting requirements than large emitters. Small emitters, for example, need not submit a full
entity-wide emissions inventory in their reporting year reports and only have to report emissions
for those activities for which they are reporting emission reductions.

A-6. Consequences of Less Frequent Reporting
The legislation requests that emissions and reductions information can be reported for 1987
through 1990 and for subsequent calendar years on an annual basis. Additionally, Section
300.8(g) of the Program’s General Guidelines requires reporting entities to report annually on a
continuous basis. This is done to ensure that the summation of entity annual reports accurately
represents net, multi-year emission reductions. It is critical that the Program maintain accurate
information on emissions, reductions, and carbon sequestration activities because greenhouse
gases and global warming are a long-term national concern and the subject of various extensive
research projects. To promote these objectives, annual collection of information is necessary.
Such annual reports allow users of the data to better analyze emission trends, reduction
activities, carbon sequestration activities, and relative participation in the Program.

11

A-7. Compliance with 5 CFR 1320.5
Data are submitted in compliance with 5 CFR 1320.5, General Information Guidelines.
Section 300.9(d) specifies certain recordkeeping requirements that reporting companies must
follow. Entities intending to register reductions must maintain adequate supporting records of
base period data for the duration of their participation in the 1605(b) program. Supporting
records for all reporting year data must be maintained for at least three years subsequent to the
relevant reporting year to enable verification of all information reported. The records should
document the basis for the entity's report to EIA.
A-8. Summary of Comments on the Federal Register Notice containing the request for a 3year extension of the Form EIA-1605 with revisions; and discontinuation of the Form EIA1605EZ.
EIA received comments from nine organizations in response to its Federal Register Notice
announcement (71 FR 42637) of July 27, 2006, containing the request for a 3-year extension of
the Forms EIA-1605 with revisions; and discontinuation of the form EIA-1605EZ.
Organizations submitting comments were the American Forest & Paper Association, American
Petroleum Institute (API), BP America, Edison Electric Institute (EEI), National Rural Electric
Cooperative Association (NRECA), Nuclear Energy Institute, Power Tree Carbon Company,
Southern Company, and Utility Solid Waste Activities Group. A summarization of the
comments by issue is provided below. The comments are also available at EIA’s website at
http://www.eia.doe.gov/oiaf/1605/public_comment.html.
It is important to note that a number of commenters raised issues (e.g., quality rating system,
reporting deadline, consistency with other reporting protocols, etc.) that would require changes
to the General and/or Technical Guidelines. EIA has no authority to change the General and
Technical Guidelines and must follow those Guidelines in implementing the revised Program.
For these reasons, comments related to General and Technical Guidelines are not discussed
below. Comments related to software design were taken under advisement and will be reflected
to the extent appropriate in EIA’s reporting software that is being developed in tandem with the
Forms and Instructions approval process. Changes related to editorial comments are also not
discussed.
General Comments
Reporting Burden
API, BP America, EEI, NRECA and Southern Company commented on the reporting burden of
submitting data the revised Form EIA-1605. API stated that EIA is grossly underestimating the
range of hours required to complete the revised forms. According to API, EIA’s estimate of 32to-64 hours per response for the revised Form EIA-1605 is far from realistic and is barely
representative of the reporting burden for very simple organizations with few locations and
emission sources. API also stated that new data quality ranking adds a new layer of complexity
12

and data management requirements that add to the burden of data collection and voluntary
reporting. API goes on to say that the best way to minimize the burden is to require reporting
that is consistent with other protocols that are already widely used such as the API Compendium.
BP America commented that the amount of information requested on the forms is very extensive,
particularly for a voluntary reporting program and this complexity is overly burdensome and
may discourage the participation of current and new reporters.
EEI stated that EIA should reconsider the accuracy of its estimates of the “burden” of the
“collection of information” and reporting thereof in preparing its submission to OMB. NRECA,
meanwhile, commented that EIA should retain the 1605-EZ form to reduce burden for small
utilities/co-operatives. Southern Company commented that the burden hour requirement for the
new program will certainly be greater than for the old program (80-100 hours for 2005 Data
Year).
EIA has taken into consideration these comments on burden in compiling its burden hour
estimates (see estimates below). First, EIA has increased its burden hour per response relative to
its request for comments. EIA has increased its burden hour estimate per reporter from 32-64
hours to a flat 60 hours per response, recognizing that large/complex entities will be above this
number while smaller, less complex entities will be below this number. Additionally, EIA has
strived to keep data elements to an absolute minimum, only requesting data required by the
General and Technical Guidelines. Also, although the form is long, the reporter will need only
do those portions of the form that apply to them. And, finally, on the issue of industry protocols,
EIA is bound to follow the methods required by the General and Technical Guidelines, as such
EIA has no ability to adopt industry protocols to reduce burden.
Reporting Versus Registering Reductions
Several commenters said that EIA should more clearly distinguish the difference between
“registering” reductions versus “reporting” reductions.
Registered reductions are designed to meet specific, stringent reporting requirements designed to
increase the credibility of reported emissions and emission reductions. Entities can register
reductions in emissions achieved beginning in 2003 and in subsequent years as measured against
a base period of up to four years (1999-2002, or later). In order to register reductions, entities
must comply with the requirements of §300.1(c) and §300.7 of 10 CFR Part 300, Guidelines for
Voluntary Greenhouse Gas Reporting. Upon review and acceptance of a report, EIA will notify
entities that reductions meeting the requirements have been credited to the entity as “registered
reductions,” which can be held by the reporting entity for use in the event a future program that
recognizes such reductions is enacted into law.
“Reported reductions” are designed to meet less stringent and more general reporting
requirements. Entities may report reductions in greenhouse gas emissions for the baseline
period of 1987 through 1990, or later and entities may report annual reductions of greenhouse
gas emissions and increases in carbon fixation realized in 1991 and subsequent years.
13

In response to these comments EIA has made a clear distinction between these two types of
reporters in both Forms and the Instructions. For entities reporting reductions, EIA now uses the
terms “reporting but not registering reductions.” For entities intending to register reductions,
EIA now uses the term “registering reductions.” Additionally, in Table 2 of the Instructions, EIA
has revised Table 2 of the Instructions to more clearly distinguish the reporting requirement by
type of reporter. And, finally, EIA added decision tree Tables 3-6 that outline the reporting
requirements by Form Schedule that a reporter would need to fill out given their reporting type
and situation.
Subentity Definition
Two commenters (EEI and Southern Company) said that EIA needed to provide clear guidance
on what constitutes a “subentity.” According to the General Guidelines a subentity “means a
component of any entity, such as a discrete business line, facility, plant, vehicle fleet, or energy
using system, which has associated with it emissions of greenhouse gases that can be
distinguished from the emissions of all other components of the same entity and, when summed
with the emissions of all other subentities, equal the entity's total emissions.” This in itself does
not specify on what grounds a reporter can establish a subentity. The grounds for establishing a
subentity are specified in section 2.2.3 of the Technical Guidelines. Generally, a subentity can
be established if a portion of the component of the entity has a unique output metric (if reporting
intensity-based or absolute reductions), distinct emission reduction methodology (distinct
Addendum B), foreign country operations, distinct base period for newly acquired operations,
changed its emission reduction methodology, or cannot practicably assess changes in its net
emissions. In response to this comment EIA has revised the Instructions to include a discussion
of permissible reasons for establishing subentities, particularly, in the Introduction to the
Instructions in the question “What are Subentities?”
Form 1605-EZ Discontinuation
EEI commented that EIA did not provide an explanation or reasons to support or justify the
discontinuance of the Form 1605-EZ. EEI claims that the best and most logical approach is for
EIA to reconstruct the so called “short form” to serve entities, large and small, that choose to
report voluntarily GHG information without meeting the “requirement” of registration. EIA,
however, decided that its original decision to discontinue Form 1605-EZ is the best decision with
respect to the Program. There is no requirement under the legislation or guidelines requiring the
“short form” and that the navigation controls of the reporting software will limit the number of
form Schedules and Sections that small emitter, and entities reporting but not registering
reductions, will be exposed to. Additionally, having a second form would increase the resource
requirements of the Program, without a significant increase in data quality or utility.
Reporting Forms
Accounting Issues – Intra-entity Energy Purchases
14

Southern Company commented that there is not sufficient guidance on how reporters should treat
intra-entity energy purchases. More specifically, if an electric power producer purchased
electricity from itself for use in its office building, how would the emissions, related to the
purchased power, be treated? In this case, EIA has revised the Form and Instructions to
emphasize that reporters should only report on energy purchases from sources outside its entity
boundary. In this situation, the intra-entity purchase of electricity would be treated as a direct
emission to the entity since it generated the electricity, rather than an indirect emission from
purchased electricity. This would prevent double-counting of the emissions related to generating
the electricity.
Accounting Issues – Geologic Sequestration
The American Petroleum Institute (API) commented that the Forms and Instructions regarding
the geologic sequestration of carbon dioxide were confusing because emissions associated with
carbon dioxide that is captured and stored (a reduction activity) are mixed in with emissions
associated with CO2 extraction, transport, and injection conducted for enhanced oil recovery, or
otherwise, that might be part of an entity’s activities included in their inventory. EIA has edited
Schedule 1, Section 2 (Entity Emissions Inventory) of the Form and Addendum B8 (Geologic
Sequestration), as well as the Instructions, to clarify this issue.
Certification
EEI and Southern Company made several comments regarding the Certification Statement in
Schedule IV. Their comments focused mainly on ensuring the Certification Statement followed
as closely as possible the certification requirements in Section 300.10 of the General Guidelines.
EIA has made a number of changes to Schedule IV, Section 2 (Reporter Self Certification) so
that it contains or references all of the certification requirements in Section 300.10 of the General
Guidelines.
Confidentiality
EEI commented that the note on question 13 of Schedule I, Section 1 that indicates that checking
the box will classify an entire report as confidential is inconsistent with the Instructions and the
Freedom of Information Act (FOIA). A review of the 1605(b) confidentiality requirements
under Section 300.9(e) of the General Guidelines states that an “entity must clearly indicate in its
1605(b) report the information for which it requests confidentiality.” EIA has edited question 13
to require respondents requesting confidentiality treatment for their reported data to clearly
indicate those data elements for which confidentiality is requested and provide a justification for
why such data should be made confidential under the Freedom of Information Act (FOIA), 5
USC Section 552(b)(4), the Department of Energy’s Freedom of Information regulations at 10
CFR Section 1004.11, and/or the Trade Secrets Act. 18 USC Section 1905.
EIA assumes that the data are not confidential and will treat them as such unless a respondent
15

requests confidential treatment. In such a case, EIA will review the request with the applicable
laws and regulations.
The Instructions have also been edited accordingly and state that upon “receipt of a request for
this information made under FOIA, the DOE shall make a final determination whether the
information is exempt from disclosure in accordance with the procedures and criteria provided in
10 CFR Section 1004.11. To assist us in this determination, reporters should demonstrate to the
DOE that, for example, their information contains trade secrets or commercial or financial
information whose release would be likely to cause substantial harm to their company's
competitive position. A letter accompanying the submission that explains (on an element-byelement basis) the reasons why the information is exempt from disclosure under FOIA, and
which specifically addresses the criteria in paragraph (f) of 10 CFR Section 1004.11, would aid
in this determination. EIA will withhold the report of a respondent requesting confidential
treatment of its reported data from the 1605(b) database until a final determination is made on
whether the data satisfies the criteria for exemption under the Freedom of Information Act
(FOIA), 5 U.S.C. §552, the DOE regulations, 10 C.F.R. §1004.11, implementing the FOIA, and
the Trade Secrets Act, 18 U.S.C. §1905.
De Minimus
API commented that portions of the Schedule 1, Section 1, Part B of the Form indicate that
nitrous oxide and methane may be assumed to be “de minimus.” API stated that if such
exceptions are allowed, the reporting entity will not be able to demonstrate that the sum of all
“de minimus” emissions meets the 3% threshold. EIA has removed this footnote and allowed for
the itemization of nitrous oxide and methane emissions.

Definition – Joint Venture
Southern Company commented that EIA did not provide a definition of “joint venture” in
Schedule 1, Section 1 in describing an Entity’s Organizational Boundaries (questions 8c). The
term was not defined in the General or Technical Guidelines. EIA’s 1605b Glossary of Selected
Terms contained in the Instructions, nor the EIA main glossary, contain a definition of joint
venture. The Legal Information Institute of Cornell Law School was searched and a definition
was found for “joint venture.” The definition adopted was “a legal organization that takes the
form of a partnership in which the persons jointly undertake a transaction for mutual profit.
Generally each person contributes assets and share risks. Like a partnership, joint ventures can
involve any type of business transaction and the “persons” involved can be individuals, groups
of individuals, companies, or corporations.
(Source:http://www.law.cornell.edu/wex/index.php/Joint_venture). This term has been
incorporated into the 1605b Glossary of Selected Terms in the Instructions.

Emission Sources

16

American Forest & Paper Association (AFPA) commented that portions of Schedule 1, Section 2
of the form do not specifically call out emissions of hydrofluorocarbons (HFCs),
perfluorocarbons (PFCs) and sulfur hexafluoride (SF6). EIA has edited these portions of the
form to call out these gases. APFA also commented that “other indirect” emissions are not to be
included in an entity’s emission inventory and it would be beneficial to include in a footnote to
this section. EIA has made this change. Southern Company also stated that it was not clear
where one could enter SF6 from electricity generation and transmission. EIA has added a row in
Schedule 1, Section 2 for this source.
Entity Boundary
EEI commented that although the Form only requires an explanation of a boundary definition
approach if an "other" method is used, the General Guidelines require an explanation for any
method except financial control. EIA has changed the form to require an explanation for any
boundary method other than financial control.
Entity Statement
National Rural Electric Cooperative Association (NRECA) commented that in the draft Form,
Schedule I, Section 1, Entity Statement, reporters are instructed in item 6 to select the category
that describes the entity. In the draft form, electric cooperatives were categorized as “Non-Profit
Organization, Cooperative.” NRECA recommends that a more appropriate categorization of
electric cooperatives would be under the “Utility (Non-Investor Owned)” category. EIA has
made this change. EEI also commented that the boxes under question 4, "Significant changes to
previous entity statements" should be revised to cover Section 300.8(f), as well as 300.5(h) of
the General Guidelines. EIA has made this change by adding a box to question 4 entitled,
"Emission reduction calculation method changed."

Offsets
EEI commented that the statement in Schedule 1, Section 3 (Emission Offsets), "…the reporter
certifies the existence of an agreement between the other reporting entity and itself…" represents
a double-certification, since Section 300.10(a) of the General Guidelines requires "a certification
statement … signed by a certifying official of the reporting entity” and Section 300.10(c)(2)(ii)
of the General Guidelines provides that such statement “must also certify that… [a]ny emission
reductions reported or registered by the entity that were achieved by another entity … are
included in the entity’s report only if … [t]here exists a written agreement with each other
entity." EIA has edited this portion of the form to make the statement more informational and to
read as, "emission reductions from another entity may only be reported if an agreement exists…"
Verification
Both EEI and API made commented to edit the verification statement in Schedule IV, Section 4
17

of the draft form to make the statement more closely conform to Section 300.11 of the General
Guidelines. EIA has edited portions of this Schedule IV so that it is in accordance with Section
300.11 of the General Guidelines.
Form Addenda
Action Identification
The Nuclear Energy Institute (NEI) commented that the question in each emission reduction
method (Addenda B) that allows reporters to “Identify Types of Actions That Were the Likely
Cause of the Reductions Achieved” should be expanded to allow reporting entities the option of
associating a numeric reduction (tons or intensity) with each action identified in this section.
EIA has not implemented this comment because there is nothing in the General and Technical
Guidelines that allows for such a designation, nor are there project-level methodologies in the
Technical Guidelines that would provide for standard calculation methods.
Definitions - Output Measures
Both EEI and AFPA commented that “output” and “indexed measure” need to be more clearly
defined in Addenda B1. EIA has edited the Instructions to better explain the concept of
“indexed” production, and has also added definitions for “indexed measure” and “output” in the
“Glossary of Selected Terms” section of the Instructions.
Equations and Form Design
Southern Company correctly pointed out that the equation for calculating emission reductions
from improvements in historical emission intensity was incorrect in Addendum B5, Part B,
question 1. EIA has corrected the formula in accordance with Southern Company’s comment.
AFPA. AFPA also commented that entry for sustainably managed forest in Addendum B3, Part
A, question 1 should automatically contain a "zero." EIA has edited this portion of the
Addendum by graying out this row so that reporters do not enter net carbon stock changes for
sustainably managed forests. Under the Technical Guidelines carbon sequestration may not be
reported for lands categorized as sustainably managed.
Unnecessary Data Collection
AFPA commented that in Addenda B1 (changes in emission intensity) and B3 (changes in
carbon stock) it does not appear relevant that EIA ask if such reductions are related to plant
closings. EIA has not changed the Addenda in response to this comment because EIA is
required to ask this question by statute (Section 1605(b) of the Energy Policy Act of 1992).
AFPA also commented that in Addendum B7 (landfill methane recovery) it is not necessary that
EIA ask for the amount of landfill waste in place in order to estimate emission reductions from
landfill methane recovery. EIA has retained this data element because it is required by the
Technical Guidelines.
18

Instructions
Accounting – Biomass Carbon Dioxide Emissions
AFPA commented that the Instructions should be edited to make it clear that carbon dioxide
emissions from biomass combustion should not be included in an entity’s emission inventory.
EIA has made changes to the Forms and Instructions to correctly accommodate this comment.
Cross Referencing
Both EEI and Southern Company commented that EIA provide specific references to the General
Guidelines in the Instructions for individual schedules and addenda. Since most of the
Instructions are based on requirements of the General and Technical Guidelines, EIA has tried to
strike a balance of referencing specific sections of the General and Technical Guidelines only
where it is believed that the reporter may need to reference the Guidelines.
Forestry
Power Tree Carbon Company commented that the Instructions regarding Carbon Losses from
Natural Disturbances is confusing and needs to be clarified. Power Tree specifically commented
that the phrase “(s)hould forestland of an entity or subentity experience a natural disturbance
such as a fire or windthrow, the carbon stocks in the disturbance year (after the disturbance)
and for the preceding years should be entered”, on page 30 of the Instructions was confusing
and should be clarified. EIA has edited this section to make it clearer. The sentence now reads,
“(s)hould forestland of an entity or subentity experience a natural disturbance such as a fire or
windthrow, the carbon stocks in the disturbance year (the year in which the disturbance occurs)
and for the preceding years should be entered.”

Language – Forestry (Pulp and Paper)
AFPA commented that the Instructions should be in conformity with the Technical Guidelines
that recognize that carbon dioxide emissions resulting from the pulp and paper industry's
conversion of calcium carbonate into lime are biogenic emissions and are not reported as part of
an emissions inventory. EIA has edited the Instructions for lime production under sectorspecific process industrial emissions.
Reporting Requirements – Recordkeeping/Decision Trees
EEI correctly commented that Table 1, Summary of Reporting Requirements in the Instructions
should be updated to note that recordkeeping requirements also apply to entities that are
reporting but not registering reductions. EIA has updated the Table accordingly. EIA has also
added to the Instructions a series of decision-tree tables to make it easier for reporters to
19

determine what schedules, sections and parts of the form they must complete.
Simplified Emissions Inventory Tool (SEIT)
De Minimus
API, Southern Company, and EEI commented that the SEIT may exclude some key emission
sources that may make it difficult to get an accurate measure of the 3 percent de minimus
emission threshold. EIA will attempt to add these sources to the SEIT to the extent possible, and
add “other” categories where possible so that reporters could enter “off-line” calculations.
The Federal Register notice (71 FR 65786) was published on November 9, 2006, announcing the
submission of the Voluntary Reporting of Greenhouse Gases survey to the Office of
Management and Budget requesting approval for a three-year extension.
A-9. Remuneration
There are no plans to compensate Form EIA-1605 respondents.
A-10. Provisions of Confidentiality of Data
Information reported on Form EIA-1605 will not be treated as confidential and will be
publicly released in identifiable form. In addition to the use of the information by EIA for
statistical purposes, the information may be used for any non-statistical purposes such as
administrative, regulatory, law enforcement, or adjudicatory purposes.
The information reported on Form EIA-1605 may be treated as confidential if a respondent
makes a written request that its information is financial or commercial information and
confidential or privileged, and they are able to satisfy the criteria for exemption under the
Freedom of Information Act (FOIA), 5 U.S.C. §552, the DOE regulations, 10 C.F.R. §1004.11,
implementing the FOIA, and the Trade Secrets Act, 18 U.S.C. §1905.
The Federal Energy Administration Act requires the EIA to provide company-specific data to
other Federal agencies when requested for official use. The information reported on the Form
EIA-1605 may also be made available, upon request, to another component of the Department of
Energy (DOE); to any Committee of Congress, the General Accounting Office, or other Federal
agencies authorized by law to receive such information. A court of competent jurisdiction may
obtain this information in response to an order. The information may be used for any
nonstatistical purposes.
A-11. Justification for Questions of a Sensitive Nature
There are no questions of a sensitive nature on the Form EIA-1605.

20

A-12a. Estimates of Reporting Burden
Assumption: The typical Form EIA-1605 reporter is assumed to be a “Large Emitter,” intends to
“register” emission reductions, files only domestic data, uses Schedule I (Sections 1, 2, and 3)
and Schedule IV (Section 2) , and does not have the information reported “Independently
Verified.”. The estimated average burden for this submission would be 60 5 hours per response.
The expected total estimated reporter burden for the 2007 reporting cycle (2006 data year) is
9,000 hours, calculated as follows:
Expected number of Form EIA-1605 Reporters = 150 6 :
150 (# of Reporters) X 1 response per year X 60 hours per response = 9,000 hours.
A-12b. Annualized Cost to the Respondents
Expected total annualized cost to the respondents for the 2007 reporting cycle (2006 data year) is
estimated to be $531,000 ----- calculated as follows:
Expected total estimated respondent burden (9,000 hours) X estimated average respondent cost
per hour ($ 59 per hour) 7 = $531,000.
A-13. Total Annual Cost Burden to the Respondent
There are no significant additional (a) capital and start-up cost or (b) total operation and
maintenance and purchase of service components associated with this data collection.
A-14. Total Annualized Cost to the Federal Government
The estimated annualized cost of the EIA’s Voluntary Reporting of Greenhouse Gases Program
information collection, processing, analysis, report writing, and data dissemination activities, for
the year 2007 (2006 data) reporting cycle is $ 637,555 calculated as follows:
Federal Personnel (0.85 Full-time Employees) 8

101,555

5 The 60 hour estimate is higher than the 40 hour estimate used for the previous version of Form-1605 because of
the increased complexity and transparency of the new Form-1605.
6 The 150 estimate of number of reporters is slightly below the estimate of 200 reporters in the last Information
Collection Request on the 1605(b) Program. The expected reduction is based on the expectation that the newness of
the Program may initially reduce participation as some reporters take a “wait and see” approach. Future reporting
years, however, will probably see larger numbers if the Program is implemented smoothly.
7
An average cost per hour of $59is used because that is the average loaded (salary plus benefits) cost for an EIA
employee. EIA assumes that the survey respondent workforce completing surveys for EIA is comparable with the
EIA workforce.
8

Based on average cost per hour of $59 as described in footnote above.

21

Contractor Support Costs:
Communications Center
Forms Review/Data Editing
Data Analysis and Report Preparation
Publication Support (review/editing/formatting)
Database and Software Maintenance/Enhancements
Other Miscellaneous Costs
Total

$

536,000
105,000
300,000
70,000
8,000
48,000
5,000
637,555

It is important to note that for the 2007 reporting cycle (2006 data), which represents the first
year of reporting under the 1605b Program Revised General and Technical Guidelines, there is
an additional start-up cost associated with the development and implementation of new
electronic reporting software (Internet-based), in the amount of $ 525,000.
It is also important to note that since reporting to the Program is purely voluntary, the contractor
support cost metrics, particularly “Forms Review/Data Editing” and “Communications Center”
are extremely sensitive to changes in level of participation and the nature of the participant. For
example: Larger Emitter” versus “Small Emitter”; “Reporter intending to register reductions”
versus “Reporter that is reporting but not registering reductions”; and type and level of
complexity of report submitted (Entity-level only, entity-level and sub-entity level, domestic
versus foreign activities, “independently verified,” “offset” reporting, “avoided emissions”
reporting, etc.) The type and level of complexity that the report reflects, is completely selfdetermined by the respondents (participants in the Program).
A-15. Program Changes or Adjustments
For the 2007 reporting cycle (2006 data) it is the expected that certain Program changes will
increase burden hours by 860 hours. An adjustment in the number of respondents is expected to
decrease burden as the number of respondents is projected to initially fall from to 150 from the
235 listed in the previous data collection. This decrease in burden, however, is expected to be
more than counteracted by an increase in hours per response to 60 hours from the 40 hours listed
in the previous data collection.
The expected burden hours estimate under this new data collection is calculated as follows:
Expected number of Form EIA-1605 Reporters = 150
150 (# of Reporters) X 1 response per year X 60 hours per response = 9,000 hours.
The previous burden hours estimate under current data collection = 8,140 hours 9
9

This is based on 200 respondents using form EIA-1605 and 35 respondents using form EIA-1605EZ.
Previous burden estimate under current data collection equals (200 respondents X 40 hours) + (35 respondents X 4
hours) = 8,140 hours.

22

Program Increase = Expected Burden - Previous Burden = 860 hours
It is important to note that this is an “increase,” and it is the result of a deliberate Federal
government action.
A-16. Publication and Tabulation Schedule for the year 2007 Reporting Cycle (2006 data)
Activity

Estimated Date

Forms available

September 2007

Filing deadline

November 2007

Information processing/data review//certification/verification complete
(Last report accepted into the database)
February 2008
Data Analysis and Report Writing Completed

March 2008

Public Use Data Base is Available

March 2008

Release of annual report

March 2008

A-17. Expiration Date
The EIA will display the expiration date of the Form EIA-1605 on the survey form.
A-18. Certification Statement
No exceptions.

B. Description of Data Collection and Survey Design
B-1. Collection of Data
Because the EIA’s Voluntary Reporting of Greenhouse Gases Program is voluntary,
participation is determined through a self-selection process. Statistical methodologies do not
apply to this ICR. The forms were developed on the working premise that the “volunteers”
have done something to either reduce greenhouse gas emissions or sequester carbon and that
these volunteers want to report and or “register” their emissions reductions achievements under
this Program. Therefore, the pool of respondents will not represent a random probability sample
of all possible reporters because the form is not designed as, nor is it used as, a statistical survey
23

instrument developed according to a recognized statistical sampling theory or methodology.
B-2. Description of Survey Design
The structure of Form EIA-1605 is designed in such a way that its level of complexity is
completely self-determined by the reporters. If reporters wish to report but not register
reductions, does not have any subentities, reports on only domestic activities and does not report
emission offset reduction, and does not employ third-party verification will probably have fairly
modest reporting requirements. Conversely, reporters wishing to register reductions, with
multiple subentities, reporting on domestic and foreign activities, with emission offsets and
employs third-party verification will have a very comprehensive, fulsome report
Under the EIA’s Voluntary Reporting of Greenhouse Gases Program, a reporting entity is a any
business, institution, organization, government agency or corporation, or household that is
recognized under any U.S. Federal, State or local law; is located and operates, at least in part, in
the United States; and, the emissions of such operations are released, at least in part, in the
United States. (Section 300.2, General Guidelines, April 2006).
B-3. Maximizing the Response Rate
EIA attempts to encourage additional responses to the Program by raising public awareness of
the Program. These efforts are focused on the issuance of the Program’s annual report,
Voluntary Reporting of Greenhouse Gases, press releases regarding significant actions, Program
Newsletters, list serve announcements and maintenance of the Voluntary Reporting section of
EIA’s website (http://www.eia.doe.gov/oiaf/1605/frntvrgg.html). EIA also participates as an
invited speaker at industry conferences to give presentations on the Program. It is important to
note, however, that the concept of a response rate is not really applicable to the Voluntary
Reporting Program because, as a voluntary survey, there is no way of identifying a number of
"desired" potential respondents or "designated" in-scope cases that can be used as the
denominator of a response rate.
B-4. Tests of Procedures or Methods
The Office of Management and Budget approved the Form EIA-1605 on May 26, 1995 (OMB
No. 1905-0194) as a recurring annual survey collection instrument. As part of that approval
process, tests of the procedures and methods were performed. Since their approval (May 26,
1995), the Form EIA-1605 has been in operational existence for 12 reporting cycles (with the
expectation of a thirteenth cycle) and has demonstrated that it is operationally successful.
C. Terms of Clearance from Previous Information Collection Request
As part of the Terms of Clearance of the last data collection approval on May 2, 2005, OMB

24

stated 10 :
“This ICR is approved for an additional two years with the understanding that EIA will
develop new reporting forms and instructions by early 2006 for collecting 2005 data as per
the revised General Guidelines for Voluntary Reporting of Greenhouse Gases Program.
OMB still views the issues that were noted in the Terms of Clearance” for the data
collection approval granted by OMB on October 16, 2001, which extended for two-years,
the previous expiration dates of the Forms EIA-1605 and EIA-1605EZ, to October 31,
2003, “with concern, and would ask EIA to take those comments into account in future
collection and analysis of data.”
EIA could not possibly meet the early 2006 date for new forms and instructions per the revised
General Guidelines because DOE did not issue Final General and Technical Guidelines until
April 21, 2006, with an effective date of June 1, 2006. This late date has pushed out the launch
of the new reporting forms and instructions to late 2007.

D. Name and Telephone Number of Program Contact Person
Should you have any questions or comments regarding this request for a 3-year extension of the
Form EIA-1605, with revisions; and for the discontinuation of Form EIA-1605EZ (short form),
please contact:
Mr. Stephen E. Calopedis
U.S. Department of Energy
Energy Information Administration, EI-81
1000 Independence Avenue, S.W.
Washington, D.C. 20585
Telephone: (202) 586-1156
FAX: (202) 586-3045
Internet E-Mail: [email protected]
E. Enclosure
Form EIA-1605 “Voluntary Reporting of Greenhouse Gases Reporting” package, which
includes:
a) Cover letter
b) Form EIA-1605
c) Instructions to Form EIA-1605

10 E-mail from [email protected] to Jay Casselberry EIA, authorized by Donald R. Arbuckle, Deputy
Administrator, Office of Information and Regulatory Affairs, May 2, 2005.

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Electronic versions (PDF ) of the Revised Form EIA-1605 and accompanying instructions, are
also available on the Internet at:
http://www.eia.doe.gov/oiaf/1605/Forms.html
If you wish to obtain additional hard copies of the enclosed documents, please:
Call 1-800-803-5182; or 202-586-0688
Write to the: Voluntary Reporting of Greenhouse Gases Program
Energy Information Administration
EI-81
U.S. Department of Energy
1000 Independence Avenue, S.W.
Washington, D.C. 20585; or
You may also contact the Program by Internet E-Mail at [email protected]

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