While some natural gas local distribution companies (LDC's) might be hoping the reporting of certain data elements required under the Mandatory Reporting of Greenhouse Gases Rule (75 FR 81350) will go away, our government will not be able to regulate emissions with measurements and estimates.
Both the EPA and the DOE’s EIA are requesting similar information and it is difficult to report accurately!Federal Regulation 40 CFR 98, subpart NN (Mandatory Greenhouse Gas Reporting to the EPA) was passed in October of 2010 and went into effect on 1 January 2011.
Under the Greenhouse Gas Reporting Program, local natural gas distribution companies (LDCs) that deliver 460,000 thousand standard cubic feet or more of natural gas per year must report the emissions that would result from the complete combustion or oxidation of the natural gas that they place in commerce. Additionally, all natural gas liquids (NGLs) suppliers must report the emissions that would result from the complete combustion or oxidation of the products that they place in commerce.
Suppliers of natural gas and NGLs are required to collect data on their products; calculate the GHG emissions associated with these products; and follow the specified procedures for ensuring data quality, amending missing data, and meeting recordkeeping and reporting requirements.
Is there any pushback from those required to submit reports under the Mandatory Greenhouse Gas Reporting to the EPA? Yes!Please see notice of hearings about the rule at
http://edocket.access.gpo.gov/2011/pdf/2011-996.pdfRecoverIR believes this rule will be modified some, but it will ultimately become law, because the United States cannot regulate energy and emissions without measurement and reporting.
What are a few factors which makes the reporting to the DOE and EPA so complex and prone to errors and inaccuracies?For more information on the complexity of reporting issues please click on the following hyperlink:
http://www.recoverir.com/regulatory_natural_gas_reporting_assistance.html