EPA’s Mandatory Greenhouse Gas Reporting Rule

General Overview

EPA’s Mandatory Greenhouse Gas Reporting Rule, 40 CFR Part 98, requires reporting of greenhouse gas (GHG) emissions from certain industries in the U.S. The rule does not require control of GHG emissions. Under the rule, Subpart W applies to the petroleum and natural gas industry segment.

Am I required to report, and when is my report due to EPA?

Emissions are required to be reported if they exceed 25,000 metric tons CO2e per year for a given facility. CO2e includes carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O), with equivalencies assigned based on the global warming potential of each pollutant.
Reports must be submitted by March 31st for the preceding calendar year.

What equipment am I required to include in my reported emissions totals?

What is included under the given
industry segment?
Emission Sources to Report
Petroleum and
Natural Gas
Includes all equipment on a well pad or
associated with a well pad, under
common ownership or control,
including leased or contracted activities
by a production owner or operator
located in a single hydrocarbon basin
Pneumatic device venting Equipment leaks
Pneumatic pump ventingReciprocating compressor
rod packing venting
Well venting for liquids
Centrifugal compressor
Gas well completion /
workover venting
Dehydrator vent stack
Storage tank emissionsAcid gas removal vent stack emissions
Combustion emissions EOR dissolved CO2
FlaringEOR injection pump
Natural Gas
Gathering and
Includes gathering pipelines and other
equipment used to collect petroleum
and/or natural gas from onshore
production gas or oil wells and used to
compress, dehydrate, sweeten, or
transport petroleum and/or natural gas
to natural gas processing facilities,
natural gas transmission or distribution
pipelines, or gas storage facilities.
Gathering pipelines operating on a
vacuum or with a GOR < 300 scf/bbl are
excluded from applicability.
Pneumatic device venting Associated gas venting /
Pneumatic pump ventingCombustion equipment
Blowdown vent stacksEquipment leaks
Storage tank emissionsReciprocating compressor
rod packing venting
Combustion emissions Centrifugal compressor
FlaringDehydrator vent stack
Acid gas removal vent stack emissions

Is this a “once‐in‐always‐in” reporting program?

You may submit a notification to EPA of your intent to discontinue reporting, if reported emissions are:
  • Less than 25,000 metric tons CO2e per year for five consecutive years; OR
  • Less than 15,000 metric tons CO2e per year for three consecutive years.
Records must be retained, and reporting must resume if annual emissions subsequently increase above the reporting