The Approach
Reporting obligations are shifting. Your risk hasn't gone away.
Federal greenhouse gas reporting has been in near-continuous revision. Requirements get proposed, extended, suspended, reinstated, and litigated, often several at once. State programs move on their own schedules. What applied to a facility two years ago may not apply today, and what does not apply today may apply again.
None of that means your obligations are gone. It means they are harder to pin down.
Most operators we meet have not re-run their applicability analysis since the last round of changes. That produces errors in both directions. Some are still reporting facilities that no longer require it, paying staff and consulting time for a submission nobody asked for. Others stood down from obligations that never lapsed and are accruing exposure they have not measured.
Both cost money. Only one of them shows up on an invoice.
The framework outlasts the rule
Even if the federal program goes quiet, somebody still wants the numbers.
Here is what gets missed in the noise around GHGRP: Subpart W is not just a federal filing requirement. It is the calculation framework that nearly everything else is built on.
State programs filling the federal gap largely adopt or mirror Subpart W methodology rather than inventing their own. Voluntary reporting programs use it. Differentiated gas certification and OGMP 2.0 reconcile against it. The EU Methane Regulation's MRV requirements expect an inventory built to a comparable standard. Corporate sustainability reporting pulls from the same underlying numbers.
So the work does not disappear when a federal proposal advances. The audience changes. An operator who dismantles the capability is optimizing for the one reader who stopped asking, while the state agency, the buyer, the lender, and the certification body all kept asking, and several are asking harder than EPA ever did.
The calculations you have already built are the asset. The question is who you are pointing them at next.
Status
Programs we support
- GHGRP Subpart W, Petroleum and Natural Gas Systems
- GHGRP Subpart NN, Natural Gas and NGL Suppliers
- GHGRP Subpart C, Stationary Combustion
- State greenhouse gas reporting programs
Other GHGRP subparts, on request
State greenhouse gas reporting programs
Voluntary and market frameworks including OGMP 2.0 and differentiated gas certification
Corporate sustainability and disclosure reporting drawing on the same inventory
Which of these reach a given facility depends on segment, throughput, ownership, and state, and the answer changes. We confirm applicability before scoping any work, and we re-check it when the rules move.
Sectors
Oil and gas is where we started, not where we stop
Most of our reporting work has been in petroleum and natural gas systems, and that is where our field measurement capability is deepest. But GHGRP applicability reaches well beyond that, and the method does not change with the sector.
The work is the same regardless of what the facility does: establish which subpart reaches it, build defensible calculations from real operating data, write a monitoring plan the site can actually follow, and produce a record that survives review. Landfills reporting under New York's Part 253 are one example. Stationary combustion sources under Subpart C are another, and those sit in nearly every industry.
If you have a facility with a reporting obligation and you are not sure the methodology is being applied correctly, the conversation is worth having whether or not you are in oil and gas.
Process
How an engagement works
- Consultation: A free call to understand your asset base and what you are currently reporting.
- Applicability review: We map your facilities against current requirements and flag gaps or over-reporting.
- Scope and schedule: A fixed scope tied to your filing calendar, with checkpoints.
- Execution: Calculations, workbooks, monitoring plans, and report preparation.
- Submission and follow-through: Filing support and response to any verification flags.
We tell you when you do not need us. Applicability work sometimes ends with "you are below threshold and you can stop reporting." We will say that. A consultant whose analysis always concludes that you need more consulting is not giving you analysis.