EHS Management Software and What It Cannot Compute
EHS software is a system of record. It handles the documents and dates well, and stores whatever emissions number you give it rather than deriving one.
Subpart W is the part of EPA's Greenhouse Gas Reporting Program that covers petroleum and natural gas systems. It is a reporting rule, separate from the OOOO emission standards, and changes to one do not change the other.
These posts track what Subpart W still requires, how the reporting deadlines have moved, and how facilities and states report greenhouse gas and methane emissions. They also cover what the published GHGRP data can and cannot tell you about a facility.
Subpart W reporting runs on its own schedule under 40 CFR Part 98, with reporting years and deadlines that EPA has moved. The posts follow those changes as they happen, note which proposals have not been finalized, and explain why state reporting rules still apply while the federal requirement is in question.
13 posts in this topic
EHS software is a system of record. It handles the documents and dates well, and stores whatever emissions number you give it rather than deriving one.
Default emission factors are Subpart W's last-ranked method for natural gas pneumatic devices, and are barred outright at sites with a supply-line flow meter.
Federal methane reporting faces suspension while Colorado ONGAEIR and New Mexico mandates stay fully enforceable. How multi-state O&G operators should respond.
The IRA methane charge was not repealed. Its rule was disapproved and the charge moved to 2034. What still binds oil and gas operators, provision by provision.
Which greenhouse gases oil and gas emits, and why the same tonne of methane becomes three different CO2e numbers depending on which published basis you use.
OGMP 2.0 Level 4 requires source-level measurement. Level 5 adds site-level reconciliation. What each level demands of your emissions data, and why.
Southern Permian oil (RRC District 7C) jumped 14% to 186M barrels in 2024. Compliance and ops implications for associated gas and methane intensity.
How Colorado operators replace the state default verification factor with an operator-specific one under Reg 7 Part B Section VIII, and when it pays off.
Dollar estimates of the CDPHE State Default Intensity Verification Factor's cost to Colorado upstream operators, with fee and sensitivity analysis.
Different methane intensity formulas produce different results for the same facility. CATF's 2026 report shows why denominator choice shapes EU compliance.
Colorado ONGAEIR report for CY2025 is due June 30, 2026. Which facilities must report, required source categories, and a pre-submission checklist for operators.
GHGRP Subpart W reporting remains mandatory in 2026. The RY2025 deadline moved to October 30, 2026. Here is what changed, what did not, and what to file.
EPA moved the RY2025 GHGRP filing deadline to October 30, 2026, while a separate proposal to suspend Subpart W reporting through 2034 remains pending.