EPA Considers Reporting Requirement Changes



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On March 22, 2010, the United States Environmental Protection Agency (EPA) proposed regulations to include additional industrial sectors to the mandatory greenhouse gas monitoring and reporting requirements finalized last year, including petroleum and natural gas systems and carbon dioxide injection and sequestration operations.

The GHG Reporting Rule, finalized in October 2009, required 31 industrial sectors to begin monitoring greenhouse gas emissions effective January 1, 2010, with annual reports due in 2011. EPA had initially considered including petroleum and natural gas systems in the original rulemaking, but in light of extensive comments, decided to defer regulation of this sector until a later date. EPA has redrafted its proposed approach for monitoring GHG emissions from this sector, recognizing that actual monitoring of the vast networks of pipelines and valves would not be practical. In the current proposal, EPA would allow most facilities to rely upon engineering estimates, emission modeling software, and emission factors to estimate their GHG emissions for purposes of the GHG reporting.

The sector covered by the proposal includes onshore petroleum and natural gas production, offshore petroleum and natural gas production, onshore natural gas processing, natural gas transmission, underground natural gas storage, liquefied natural gas (LNG) storage, LNG import and export, and natural gas distribution. Covered sources will be required to begin collecting data in 2011, with their first GHG emission reports due to EPA in March 2012. EPA estimates that 3,000 facilities will be required to report, of which more than half are not currently reporting.

In addition to the petroleum and natural gas systems sector, EPA has proposed monitoring and reporting requirements for facilities that inject carbon dioxide into the ground, either for geologic sequestration or for enhanced oil and gas recovery.

Both of these proposals remain open for public comment through June 11, 2010.
Kathy Milenkovski
Huntington Center
41 South High Street, Suite 2200
Columbus, OH 43215



Of Counsel
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