Greenhouse Gas Reporting Program – Petroleum and Natural Gas

Greenhouse Gas (GHG) Reporting Rule (40 CFR 98 Subpart W).

The Greenhouse Gas Reporting Program (GHGRP) (codified at 40 CFR Part 98) requires reporting of greenhouse gas (GHG) data and other relevant information from large GHG emission sources, fuel and industrial gas suppliers, and CO2 injection sites in the United States. The GHGRP covers emissions from different aspects of the oil and gas industry through several of its subparts. Annual reports covering emissions from the prior calendar year are due by March 31 of each year.

Reporting requirements for Petroleum and Natural Gas Systems are found at 40 CFR Part 98 Subpart W. The source category consists of the following industry segments:

  • onshore petroleum and natural gas production,
  • offshore petroleum and natural gas production,
  • onshore petroleum and natural gas gathering and boosting,
  • onshore natural gas processing,
  • onshore natural gas transmission compression,
  • onshore natural gas transmission pipeline.
  • underground natural gas storage,
  • liquefied natural gas (LNG) import and export equipment,
  • LNG storage, and
  • natural gas distribution.

Other segments of the petroleum and natural gas industry are covered by the GHGRP but not included in the Petroleum and Natural Gas Systems (Subpart W) source category, such as Petroleum Refineries (Subpart Y), Petrochemical Production (Subpart X), Suppliers of Petroleum Products (Subpart MM), and Suppliers of Natural Gas and Natural Gas Liquids (Subpart NN).

A facility in the Petroleum and Natural Gas Systems source category is required to submit annual reports it total emissions are 25,000 metric tons or more of CO2 equivalent per year.

Important Definitions Found in Subpart W

In general, a "facility" for purposes of the GHGRP means the following:

Facility means any physical property, plant, building, structure, source, or stationary equipment located on one or more contiguous or adjacent properties in actual physical contact or separated solely by a public roadway or other public right-of-way and under common ownership or common control, that emits or may emit any greenhouse gas. Operators of military installations may classify such installations as more than a single facility based on distinct and independent functional groupings within contiguous military properties. However, Subpart W has specialized definitions of “facility” for the following industry segments:

  • Onshore petroleum and natural gas production,
  • Onshore petroleum and natural gathering and boosting,
  • Onshore natural gas transmission pipeline, and
  • Natural gas distribution.

Facility with respect to onshore petroleum and natural gas production means all petroleum or natural gas equipment on a single well-pad or associated with a single well-pad and CO2 EOR operations that are under common ownership or common control including leased, rented, or contracted activities by an onshore petroleum and natural gas production owner or operator and that are located in a single hydrocarbon basin as defined in §98.238. Where a person or entity owns or operates more than one well in a basin, then all onshore petroleum and natural gas production equipment associated with all wells that the person or entity owns or operates in the basin would be considered one facility.

Facility with respect to onshore petroleum and natural gas gathering and boosting means all gathering pipelines and other equipment located along those pipelines that are under common ownership or common control by a gathering and boosting system owner or operator and that are located in a single hydrocarbon basin as defined in this section. Where a person owns or operates more than one gathering and boosting system in a basin (for example, separate gathering lines that are not connected), then all gathering and boosting equipment that the person owns or operates in the basin would be considered one facility. Any gathering and boosting equipment that is associated with a single gathering and boosting system, including leased, rented, or contracted activities, is considered to be under common control of the owner or operator of the gathering and boosting system that contains the pipeline. The facility does not include equipment and pipelines that are part of any other industry segment defined in this subpart.

Facility with respect to natural gas distribution means the collection of all distribution pipelines and metering-regulating stations that are operated by a Local Distribution Company (LDC) within a single state that is regulated as a separate operating company by a public utility commission or that are operated as an independent municipally-owned distribution system.

Facility with respect to the onshore natural gas transmission pipeline segment means the total U.S. mileage of natural gas transmission pipelines, as defined in this section, owned and operated by an onshore natural gas transmission pipeline owner or operator as defined in this section. The facility does not include pipelines that are part of any other industry segment defined in this subpart.

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