EPA Proposes Mandatory GHG Reporting Including O&G Facilities
With the ink barely dry on the first-ever mandatory greenhouse gas (GHG) reporting requirement, originally proposed in 2009, the U.S. EPA has set forth new and sweeping proposals for mandatory reporting that will significantly impact natural gas facilities, including offshore. This encompasses all equipment associated with production, collection/transmission, storage, and treatment, and will cover combustion-related, fugitive, and vented emissions sources.
With the public comment period ending on June 11, 2010 and the final rules expected in late summer or early fall, only months remain to prepare and implement a monitoring and reporting plan. Under the proposed rule, collection of emissions data would begin January 1, 2011, with the first annual reports due to the EPA by March 31, 2012.
Producers should be especially alert to the latest definition of a facility for reporting requirements, which has been expended to include all permits held by an operator within a production basin. Accordingly, one industry expert estimates that "a gas field with 34 wells and associated equipment would trigger the reporting threshold of 25,000 metric tons of CO2e (carbon dioxide equivalent)."
For more information go to the EPA's site:
Source: US Environmental Protection Agency, 40 CFR Part 98.230, Proposed Mandatory Reporting of Greenhouse Gases from Petroleum and Natural Gas Systems – Subpart W, 3/22/10
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