Subpart W: Lessening the Burden of GHG Reporting

Subpart W: Lessening the Burden of GHG Reporting
While we all wait to see what changes occur on the federal level, and how the market responds, important changes in how the industry carries out regulatory reporting are ongoing.

This opinion piece presents the opinions of the author.
It does not necessarily reflect the views of Rigzone.

2017 is set to be a fascinating regulatory year in the oil & gas industry.

While we all wait to see what changes occur on the federal level, and how the market responds, important changes in how the industry carries out regulatory reporting are ongoing.

Gary Vegh
Gary Vegh
Chief Toxicologist

A perfect example is how the reporting needs of Subpart W of the Greenhouse Gas Reporting’s program will now be able to utilize the same dataset of information gathered from existing New Source Performance Standard (NSPS) OOO (Quad O) and/or OOOOa (Quad Oa) reporting processes.

This is a good indication of how, while we await further developments from major regulatory bodies, key reporting programs are still being adjusted and refined. 

It represents a small but crucial realignment, which will streamline the way oil & gas producers carry out their federal reporting. It will specifically impact any facilities that are engaged in NSPS Quad O and/or Quad Oa reporting, spelling out an easier process for sites that are engaged in this reporting.

What facilities need to sit up and take notice? 

Any facilities in the United States carrying on with the following activities will need to take heed of this change:

  • Production
  • Gathering and Boosting
  • Distribution and Transmissions Pipelines
  • Liquefied Natural Gas (LNG) Import and Export Equipment
  • LNG storage
  • Underground Natural Gas Storage
  • Transmissions Compression

According to the published definitions, any facility that emits more than the established threshold of 25,000 metric tons of carbon dioxide (CO2) per year will fall into the ‘required to report’ bracket.

Midstream partners in particular, operating substantial amounts of transfer pipelines, storage facilities, tanks, and other equipment will inevitably have to pay attention to the smaller “fugitive” emissions that the NSPS cover.

The good news is that this process will have gotten one step shorter due to this change.

Facility managers and compliance role-holders will breathe a sigh of relief in knowing they have one less set of information to deal with this year. Nevertheless, the deadline for Greenhouse Gas Reporting is set for March 31, and facilities will need to ensure that they are organized, have fully accurate reports ready and are prepared to submit by that date.

Why This Change and Why Now?

Part of the reasoning behind the emergence of this new reporting process is that it will further promote robust reporting in a dynamic and changing domestic energy market.

With the boom in hydraulic fracturing over recent years, the number of firms engaged with that method of oil and gas production has skyrocketed.

In addition to the growth in hydraulic fracturing, the comparatively lower production cost of producing LNG means that many more established firms involved with this product are ramping up production across the United States. An improved export scenario further underpins this healthier production environment.


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