CLIMATE CHANGE AND ENVIRONMENTAL UPDATE

EPA Seeks Corporate Ownership Information Under Greenhouse Gas Reporting Rule and Expansion of Reporting Obligations to Additional Oil and Gas Facilities

April 8, 2010

Facilities subject to the U.S. Environmental Protection Agency's ("EPA") greenhouse gas ("GHG") reporting rule are currently required to monitor their GHG emissions and, beginning in March 2011 and annually thereafter, report their emissions data for the preceding calendar year.  EPA recently proposed amending its reporting rule to require disclosure of corporate ownership and industry classification details.  EPA is soliciting input on exactly what ownership information it should require, but options include identifying either the highest level U.S. parent company with the largest ownership interest in the reporting entity or all top level U.S. parent companies and their respective ownership percentages. EPA expects that such information will allow it to better understand the aggregate GHG emissions of individual companies, as well as larger industry sectors, and help inform the development of future climate change regulations. 

 

EPA has also formally proposed requiring emissions data from additional petroleum and natural gas systems not included under the existing rule, beginning for emission year 2011.  The expanded scope would include fugitive, vented and flare combustion emissions from certain petroleum and natural gas facilities that emit 25,000 metric tons or more of carbon dioxide equivalent, including onshore and offshore production; onshore natural gas processing; onshore natural gas transmission compression; underground natural gas storage; liquefied natural gas storage, import and export; and natural gas distribution facilities.   The proposal would modify the definition of “facility” so as to aggregate certain equipment into a single emission source for reporting purposes.  EPA estimates the proposed amendment would encompass approximately 1,800 facilities that are not currently subject to the existing reporting rule.

 

See EPA Proposed Rule for Corporate Parent Information

See EPA Proposed Rule for Petroleum and Natural Gas Systems

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