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EPA Proposes GHG Reporting Rule Revisions for Petroleum and Natural Gas Systems

Posted Friday, March 7th, 2014

The U.S. Environmental Protection Agency (EPA) has proposed revisions and confidentiality determinations for the Greenhouse Gas (GHG) Reporting Rule.  Specifically, the proposal addresses the petroleum and natural gas systems source category (40 CFR 98, Subpart W) and the general provisions (40 CFR 98, Subpart A), and proposes to revise certain monitoring and data reporting requirements, revise certain calculation methods, clarify certain definitions, and propose confidentiality determinations.

Most notably, the proposal eliminates the best available monitoring methods (BAMM) provisions, which currently allow the use of alternative GHG emissions calculation methods in order to give facilities adequate time to adopt the required methods.  EPA explains in the proposal that the BAMM provisions were never intended to be used indefinitely, but instead were designed to serve as a “bridge” to full compliance where reasonable impediments to monitoring exist.  The proposal would also revise calculation methods for numerous sources, including liquids unloading, well completions, workovers, storage tanks, venting and flaring, and natural gas distribution sources.

The proposal would also require reporters to calculate GHG emissions in metric tons of each individual GHG, as opposed to metric tons of CO2 equivalent.  EPA explains that this would promote consistency between the requirements of the petroleum and natural gas sector and the other sectors subject to the rule.

Certain definitions would also be revised under the proposal, including the source category definition and the “sub-basin category” definition.  The source category definition would be revised to include references to “all equipment on a single well-pad or associated with a single well-pad.”  EPA explains that the revised definition is not intended to alter the amount of sources subject to the rule, but rather to more accurately describe the sector for purposes of GHG reporting.  The definition of “sub-basin category” would be revised by dividing it into five formation types: oil, high permeability gas, shale gas, coal seam, and other tight gas reservoir rock.

The proposal also includes confidentiality determinations for new and substantially revised data reporting elements and a revised confidentiality determination for one existing data reporting element.  EPA has proposed that none of these data reporting elements are entitled to confidential protection.

If finalized, the proposed revisions would become effective on January 1, 2015.  Comments on the proposal are due April 24, 2014.  For additional information, contact Andrew Holway.


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