Cost of Compliance with EPA's Mandatory GHG Reporting Rule, Subpart W for Onshore Oil and Natural Gas Production

摘要

Based on industry experience with reporting under the GHGRP, the actual costs of complying with Subpart W for onshore oil and natural gas production companies is significantly (more than 60 times) higher than EPA's estimates. The information collected from the industry survey is based on actual companies' experience with the GHGRP and furthermore, based on this practical experience, provides an estimate of the burden associated with ongoing compliance with the GHGRP. The fact that costs are substantially higher than the government originally estimated suggests that EPA should work to reduce the reporting burden. EPA should work collaboratively with reporters to learn from their experience and examine the practical utility of reporting all the data, as well as its collection frequency, in order to explore ways to meet Agency data needs while reducing the burden the GHGRP places on industry on an ongoing basis. After a finite duration of reporting, such as five years for a particular sector, EPA could undertake a review of the data reported with the goal of prioritizing the largest, and truly significant, emission sources for each of the sectors. EPA could then consider options, which might include sunsetting the reporting program, or less frequent reporting, or a more focused approach that centers only on the most significant emitting sources. EPA could adjust the latest reported GHG emissions data for a sector annually based on an increase or decrease in production or activity parameters for that sector, should GHG reporting be sunset or required less frequently. Such a modified reporting approach would lessen the reporting burden while still providing GHG data for policy decisions.