U.S. EPA is proposing to add emissions sources to its mandatory greenhouse gas (GHG) reporting program, including onshore petroleum and natural gas production, processing, transmission and storage facilities (see here). Its rationale: "Fugitive and vented GHG emissions from this industry (i.e., the petroleum and natural gas industry sector) are the second largest source of human-made methane emissions in the United States *** and represent a critical addition to the emissions data that EPA is already collecting under other parts of the MRR [Mandatory Reporting Rule]."
Facilities that emit 25,000 metric tons or more of CO2 equivalent per year would be captured in the program. Notably, "[d]ue to the unique characteristics of these industry segments, the proposed definition of ‘facility’ for onshore and offshore petroleum and natural gas production, and natural gas distribution differ from the definition of facility applied in the remainder of the MRR." For production facilities, the relevant definition proposed by EPA:
Onshore petroleum and natural gas production facility means all petroleum or natural gas equipment associated with all petroleum or natural gas production wells under common ownership or common control by an onshore petroleum and natural gas production owner or operator located in a single hydrocarbon basin as defined by the American Association of Petroleum Geologists which is assigned a three digit Geologic Province Code. Where an operating entity holds more than one permit in a basin, then all onshore petroleum and natural gas production equipment relating to all permits in their name in the basin is one onshore petroleum and natural gas production facility.
A public hearing has been scheduled for April 19, 2010, in Arlington, VA. The comment period will be open for 60 days following publication in the Federal Register.