EPA proposes revisions to greenhouse gas reporting rules for petroleum and natural gas systems

The U.S. Environmental Protection Agency (EPA) has proposed revisions to its greenhouse gas reporting rules for the oil and gas industry. Published in the March 10, 2014 edition of the Federal Register, 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).

The proposed changes include revisions to “certain calculation methods, monitoring and data reporting requirements, terms and definitions, and technical and editorial errors…” as well as proposing “confidentiality determinations for new or substantially revised data elements” in the rules.

The revised reporting rule eliminates the Best Available Monitoring Method (BAMM) provision which currently allows the use of alternative engineering calculations or supplier data to determine greenhouse gas emissions.

According to the EPA, the “proposed revisions to calculation methods would provide greater flexibility and potentially reduce burden to facilities,…and increase clarity and congruency of calculation and reporting requirements…” by increasing options for calculation of emissions from various sources, such as compressors, natural gas pneumatic device venting, acid gas removal vents, dehydrators, liquids unloading, gas well completions, workovers, venting and flaring, storage tanks, and natural gas distribution sources.

Separate reporting of emissions of each of the six key greenhouse gases (carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride) in metric tons would be required – rather than simply reporting the total carbon dioxide-equivalent emissions.

These proposed revisions are open for public comment until April 24, 2014. If finalized, these revisions would become effective on January 1, 2015.

This post was written by Barclay Nicholson (barclay.nicholson@nortonrosefulbright.com or 713.651.3662) from Norton Rose Fulbright's Energy Practice Group.