GHG Reporting - Subpart W, brief summary

"EPA has changed the proposal in three ways. First, the rules add two new reporting segments within the sector—onshore petroleum and natural gas production and natural gas distribution facilities. Second, the rule seeks to reduce the burden on the regulated community by taking a new approach to emissions monitoring in the sector. EPA’s previous proposal relied heavily on comprehensive leak detection and direct measurements for capturing emissions data. Because emissions sources in this sector are relatively diffuse, i.e., thousands of miles of pipelines and valves, EPA recognized that direct emissions monitoring would impose a significant cost on the industry. As a result, EPA’s current proposal allows most facilities to measure emissions through engineering estimates, emission modeling software, and emission factors.[4] Third, EPA seeks to alleviate confusion caused by the previous proposal by providing separate definitions for “vented” and “fugitive” emissions instead of collectively defining both sources as “fugitive.”

"EPA’s proposal requires facilities that emit greater than 25,000 metric tons or more per year of CO2 equivalent to report their GHG emissions. Due to the diffuse nature of the storage facilities, wells, and associated pipelines in the industry sector, the proposal contains three different “facility” definitions for three different industry segments, all of which differ from the definition provided in the 2009 GHG Reporting Rule. For example, a facility in the onshore petroleum and natural gas production segment is defined to include all petroleum or natural gas equipment associated with production wells that are under common ownership or control and within one hydrocarbon basin.[5] Therefore, unlike the 2009 GHG Reporting Rule, an onshore production “facility” need not be connected or even located on adjacent properties; rather, the total fugitive and vented emissions from an unconnected network of wells, pipelines, and processing facilities would count towards the 25,000 metric ton reporting limit. Unique facility definitions are also provided for the offshore petroleum and natural gas production and natural gas distribution industry segments."

EPA Releases Additional Proposed Greenhouse Gas Emissions Reporting Rules for Three Industry Sectors Marten Law