This program aims to track human-driven sources of greenhouse gas emissions across all industries in the US. Reporting requirements regarding methane emissions for oil and gas operators are outlined in Subpart W of the EPA mandatory reporting code.
As part of the GHGRP, the EPA produces an annual Greenhouse Gas Inventory (GHGI). The EPA recently proposed an update to its collection methodology for the GHGI that will require operators to not only report any emission greater than the threshold outlined in Subpart W, but also to provide a start and end date for each emission. If the operator cannot prove the start date, the EPA will assume a minimum leak duration of 91 days. Leak duration is an important part of the fee calculation for Waste Emissions Charges.
While the rule is still being finalized, we believe it is prudent to assume the final rule will largely resemble the proposed rule with a few key changes that will allow greater flexibility in the technologies allowed to satisfy monitoring and reporting requirements.