Q110. If two entities share a Title V permit would that preclude them from reporting separately even if there is no common ownership or control?

A110. EPA has determined that the Title V definition of facility is not appropriate for this GHG reporting rule. The GHG rule serves a different purpose than Title V programs and therefore defines a facility in a way that is more inclusive of all large emitters. Under the facility definition in the GHG rule, if there is no common ownership or common control, then the facilities would be separate and their emissions would be reported separately.