Greenhouse Gas Reporting Protocols for Natural Gas Suppliers

DEQ has extended the reporting deadline for the first reporting year. In 2011 only, for the 2010 emissions year, natural gas suppliers must register and report their annual greenhouse gas emissions by April 30, 2011. Beginning in 2012 for the 2011 and future emissions years, natural gas suppliers must register and report their annual greenhouse gas emissions by March 31 following the emissions year using DEQ-approved reporting protocols.

Oregon rules require natural gas suppliers to report the type and quantity of the natural gas sold and distributed for use in Oregon during the previous year (Jan. 1 through Dec. 31), and the greenhouse gas emissions that will result from the combustion of the natural gas. All natural gas suppliers must calculate and report these greenhouse gas emissions this form.

For purposes of greenhouse gas reporting, there are three categories of natural gas suppliers:

1. Local distribution companies: Natural gas suppliers operating as local distribution companies that meet the source category definition in 40 C.F.R. Part 98 Subpart NN (Suppliers of Natural Gas and Natural Gas Liquids, which EPA finalized Oct. 30, 2009) should use either the default high heat values and emission factors in the form or values specific to their fuel as measured using the monitoring and QA/QC requirements in Subpart NN.
2. Interstate pipelines
: A company operating interstate pipelines should monitor and measure the volume of natural gas supplied to Oregon in accordance with the transmission company's current gas tariff filed with Federal Energy Regulatory Commission (FERC). Companies should use either the default high heat values and emission factors in the form, or use values specific to the gas they supplied as measured using the gas quality standards and measurement requirements specified in the General Terms and Conditions of their FERC Gas Tariff.
3. Intrastate pipelines: We are not aware of any intrastate pipelines operating in Oregon that fall under the applicability criteria described above. If an intrastate pipeline begins operation in Oregon that may be subject to Oregon's greenhouse gas reporting rule, DEQ will work with them to develop appropriate protocols for monitoring and reporting the volume of natural gas they distribute to end users in the state.

Businesses required to report to DEQ and EPA: Some businesses required to report greenhouse gas emissions to DEQ are required to report emissions to EPA. To simplify reporting from these businesses, they can provide DEQ a copy of the report submitted to EPA in place of registering and reporting separately to DEQ.

However, Oregon rules authorize DEQ to require the submission of additional information if the copy of the report submitted to EPA is not sufficient to determine greenhouse gas emissions and related information that are otherwise required by Oregon rules. A business's report must delineate the emissions for natural gas distributed for use in Oregon. If the copy of the business's report to EPA doesn't delineate emissions for Oregon, the businesses should calculate and report Oregon-specific emissions using the protocols and form described above.

DEQ wants Oregon's greenhouse gas reporting protocols and requirements to be consistent with EPA wherever possible to prevent duplicative reporting. However, because the EPA reports for 2010 emissions are deferred, facilities will need to file a separate report to DEQ for the 2010 emissions year and adhere to Oregon's reporting deadline specified above. Visit EPA's website to learn about recent changes to the federal program.

Natural gas suppliers must mail a signed copy of their Oregon greenhouse gas report to DEQ at:

Oregon DEQ
Air Quality Division
Attention: GHG Program
811 SW Sixth Ave.
Portland, Oregon 97204