A Deep Dive into Methane Emissions Reporting Frameworks

Analyzing the Global Methane Pledge, OGMP 2.0, and IMEO for regulatory coherence.

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Maryam Irfan
10/25/2024

When multiple agencies operate in the same space, regulatory incoherence becomes a real risk, especially if they are moving in the same direction. The different offices within the EPA as well as the Department of Transportation under PHMSA all seek to regulate methane emissions, which can create situations where one EPA office might not be fully aware of what another office, or PHMSA is doing.

In an interview with the Industrial Decarbonization Network, Ryan Steadly, Senior Policy Advisor in API’s Upstream Policy Division pointed out that “from a practical perspective, it's not necessarily the EPA's or PHMSA’s job to know what the other is doing, but at a higher level, coordination is crucial.”

READ THE FULL REPORT | Dissecting the U.S. Methane Regulation Landscape: Key Policies and Future Direction

For instance, the EPA’s methane rule uses a detection metric for alternative technologies in kilograms per hour, whereas PHMSA developed a standard that requires detection in parts per million, a completely different method that limits the scope of technologies that can be used. This disconnect creates challenges, particularly for midstream operators who may need to perform EPA surveys on compressors while also complying with PHMSA regulations. Harmonizing these requirements would allow operators to, for instance, use a flyover with a sensitive detection instrument that measures in kilograms per hour, rather than having to employ different methods for different rules.

In December 2023, the U.S. Department of Energy’s (DOE) Office of Fossil Energy and Carbon Management (FECM), announced the formation of an international working group called the GHG Supply Chain Emissions Measurement, Monitoring, Reporting, and Verification (MMRV) framework. This was formed to develop comparable, shared, and credible data on GHG emissions across the natural gas supply chain, from production through delivery. Various importing and exporting countries, and other domestic stakeholders have partnered with the DOE to develop this framework. Importantly, it includes a process to confirm the use of consistent protocols including the independent supervision and verification of the accreditation process. Additionally, the FECM also provides funding to develop and deploy advanced technology solutions to increase efficiency, reliability, and methane mitigation across the oil and natural gas infrastructure.

Moreover, as methane reduction becomes central to most global warming mitigation initiatives, there is an urgent need for emissions reporting and technical frameworks to establish consistent standards across the oil and gas industry. This is particularly important as various countries have different policy approaches which makes some standardization imperative.

International-level initiatives are crucial to create conditions that support and incentivize methane mitigation at a scale. Here, we look at three international-level frameworks, highlighting their importance in emissions reporting along with the gaps to be aware of.

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1. Global Methane Pledge (GMP)
One example of such a framework is the Global Methane Pledge (GMP), which supports countries to collectively reduce methane emissions by 30% by 2030, as compared to 2020 levels. Launched in 2021 by the U.S. and the European Commission, the GMP works across six areas including energy, waste, food and agriculture, methane policies, emissions data, and financial assistance.

What’s missing?
According to a 2023 study by the Environmental Investigation Agency (EIA), the framework is currently unable to deliver the desired results due to inadequate funding and shortcomings in its governance framework. In fact, the funding for methane mitigation stands at less than two percent of the overall funding made available to fight climate change. Moreover, the Pledge’s funding is project-based and unpredictable, thereby restricting countries to addressing only some parts of their methane emissions, which creates gaps in their efforts.

2. Oil and Gas Methane Partnership (OGMP 2.0)
Another is the Oil and Gas Methane Partnership (OGMP 2.0), a voluntary international oil and gas methane emissions reporting framework launched by the United Nations Environment Program (UNEP). Its members include over 140 companies with assets in over 70 countries, accounting for almost 40% of the global oil and gas production. They provide annual corporate-wide reporting of methane emissions from all operated and non-operated assets, at a granular level.

What’s missing?
The OGMP 2.0 was not conceptualized and designed as a regulatory compliance framework but as an investment standard. It also doesn’t track emissions across natural gas supply chains, including shipment-level data, and therefore might not be able to give a complete picture of the existing scenario. Additionally, asset-level data needed to derive a methane intensity assessment for Liquid Natural Gas (LNG) cargoes or discrete pipeline volumes is classified and available only to the UNEP OGMP 2.0 team, creating bottlenecks.

3. International Methane Emissions Observatory (IMEO)
Another emissions reporting framework is the International Methane Emissions Observatory (IMEO), formed by the United Nations Environment Program (UNEP) and the European Commission (EC). It collects and publishes data from its Methane Science Studies, from satellites via the Methane Alert and Response System (MARS), through the Oil and Gas Methane Partnership 2.0 (OGMP 2.0), and from national emissions inventories.

What’s missing?
The database is currently still under development and companies need to wait for around five years to get level 5 designations for their material operated and non-operated assets.

Addressing Inconsistencies
The process of promulgating regulations in the U.S. is a lengthy one, which allows for multiple phases of interaction between regulators and the regulated entities. For instance, the EPA can have ongoing conversations with the oil and natural gas industry as the regulated entity, which is a positive aspect.

During a recent interview with the Industrial Decarbonization Network, Dr. Aaron Padilla shared that even after the EPA issues final rules, the Clean Air Act allows regulated entities like the oil and gas industry to petition the EPA to reconsider aspects of the regulations that we believe may be inaccurate or impractical to implement. He further shared that the API has taken advantage of this opportunity to request reconsideration on certain items. Currently, they are in the middle of that dialogue and reconsideration process for two of the three main methane regulations in the United States. The third regulation, the waste emissions charge, is still to be finalized, which will complete the picture for the industry.

The best way to achieve effective coordination is through a dialogue that delves deeply into the technical substance of the rulemaking. The U.S. onshore industry is highly complex, producing significant quantities of oil and natural gas across various basins, each with different characteristics, such as oil versus gas production, conventional versus unconventional methods, and other variables that impact methane emissions. Therefore, it requires a detailed technical dialogue, underpinned by a mutual recognition that both regulators and regulated bodies are striving for the same goal. Fortunately, according to Dr. Aaron Padilla, the U.S. has reached a point where the industry has expressed support for the direct federal regulation of methane from oil and gas operations, both for new and existing sources. This has provided a platform of common ground with the EPA for these discussions.

“We don't always see eye to eye! The regulators sometimes propose measures that are too stringent, lack a cost-benefit balance, or are impractical for us to implement. When this happens, we point out the issues and engage in a regular back-and-forth. Thankfully, we are still in the midst of that process and are working to get it right here in the U.S.” - Dr. Aaron Padilla, Vice President of Corporate Policy at American Petroleum Institute (API).