APGA and the Environmental Protection Agency (EPA) have reached an agreement that would exempt small natural gas utilities (LDCs) from complying with annual EPA greenhouse gas (GHG) reporting requirements.  The exemption would apply only to gas systems that emit fewer than 25,000 metric tons of emissions each year, which is the equivalent of 460,000 MCF throughput.  LDCs with emissions larger than 25,000 metric tons are still required to comply.  The agreement calls for EPA to issue a proposed rule to provide the small LDC exemption.  EPA will need to issue a proposed rule, take comments, and ultimately issue a final rule to set the exemption in stone.  APGA is reasonably optimistic EPA will complete these actions before first reports are due next March.   

The EPA GHG Reporting Rule was published on December 29, 2009.  APGA challenged the rule in the DC Circuit Court of Appeals arguing that the rule would disproportionately impact small utilities.  APGA argued that the regulatory burden on small utilities overwhelms the miniscule amount of data the agency would receive from these entities.  EPA decided to settle with APGA and agreed to exempt small gas LDCs.     

For those larger utilities the rule requires annual reporting of annual volumes of gas delivered by LDCs broken down into certain categories beginning with Calendar Year 2009.  The certificate of representation is due to EPA on January 31, 2011.  The date for the first report is March 31, 2011.  The Rule also requires that each LDC covered by the Rule maintain information to allow EPA to verify the accuracy of the volumes reported.

You can find further information on this rule and the EPA’s newly developed GHG electronic monitoring and reporting system at http://www.epa.gov/climatechange/emissions/data-reporting-system.html.  

You can visit www.apga.org to find resources that will help public gas systems calculate emissions and put together a GHG monitoring plan. 

For more information on this rule and other EPA actions contact Nate Hill or John Erickson at 202-464-2742 or nhill@apga.org or jerickson@apga.org.  

Return to Archives