Development of GHG Emissions Data Management Strategies for Rapidly Growing Requirements

Project Summary

Montrose’s Advisory business line supported a midstream oil and gas for several years to collect data, perform calculations, and submit greenhouse gas (GHG) emissions under the EPA’s mandatory reporting rule. As the organization continues to experience substantial growth, Montrose has played a role in helping this organization establish standards to assist with its data management processes, including high-level data validation, building automated processes that include electronic reporting and data integration, and enabling them with data needed to drive decision-making. Over time, Montrose expanded the analyses beyond internal data and benchmarked the customer’s data against competitors to identify areas for potential reductions and enable stakeholders to make informed decisions based on industry trends and best practices.

Challenge

As the operations expanded, the complexity of managing already vast amounts of reporting GHG data increased significantly. Initially, the GHG reporting data collection process was managed by a small team of EHS professionals who were required to request, compile, and validate the quality of the data before inputting it into an emissions management software. However, the increase of data management requirements necessitated the delegation of data collection responsibilities throughout the organization, including to field-level personnel. This decentralization introduced challenges in establishing effective processes to ensure data accuracy and consistency being input into the reporting software. Consequently, the client experienced numerous data validation issues, leading to the submission of inaccurate data to the EPA, resulting in rejections and subsequent resubmissions. The effort required to prepare resubmittal reports was substantial, underscoring the need for a more robust data management and validation system that could highlight outliers within the internal data set and compare the data against industry expectations.

Our Role

The Montrose team leveraged their expertise in data management, data analysis, and regulatory compliance to develop a comprehensive Business Intelligence (BI) tool. This tool identifies specific data accuracy issues that could be flagged by the EPA and require resubmissions. Our team extrapolated this data and compared it against publicly available data to detect any deviations from industry averages. This process helped to detect potential outliers, strengths, risks, opportunities, and performance metrics relative to their competitors. Most recently, our team conducted a preliminary analysis of methane tax exposure, comparing it to industry expectations and identifying areas for improvement to proactively reduce exposure to the tax.

Solution

To address the client’s challenges, Montrose developed a Business Intelligence (BI) tool designed to streamline data management and improve accuracy through repeatable practices. This tool is equipped with:

Validation routines that reflect the EPA’s checks for potential issues, highlighting inaccuracies prior to submittal.
Publicly available GHG data from Subparts C, D, W, and X and associated intensity calculations to benchmarking performance against competitors.
Granular insight into equipment-level emissions to better understand material emission sources and make comparisons to industry averages to allow for an understanding of reduction opportunities and potential risks.
Analysis of exposure to new methane tax regulations, including forecasting potential emissions calculated under the new methodology, enabling clients to plan measurements and reductions more effectively.

These features provide a comprehensive solution for managing and validating data. The integrated EPA validation checks allow the client to identify and correct inaccuracies before submission, thus reducing error rates and minimizing compliance delays caused by resubmissions. The tool’s robust data visualization capabilities offer detailed insights at both facility-specific and broader organizational levels, helping the client to track and trend data over time. This capability is crucial for identifying outliers and quickly addressing errors with the responsible data entry personnel, especially given the previous issues with decentralized data entry.

The dashboards for general GHG emissions trending, equipment-specific intensity measurements, and breakdowns of emissions by source type provide the client with actionable insights into their emissions profile. This helps in understanding material emission sources, comparing them to industry benchmarks, and discovering opportunities for emission reductions. Additionally, the analysis of methane tax exposure supports proactive planning and strategic adjustments to mitigate potential tax impacts, ensuring the client remains compliant with evolving regulations.

Result

By utilizing this tool, the customer was able to:

Validate reportable data more comprehensively, despite the increased volume of data and decentralized data collection and entry responsibilities.
Substantially reduce the number of resubmissions required by addressing data issues prior to submittal.
Make informed operational adjustments, leading to more accurate emissions reporting and better compliance with EPA regulations. Specifically, the client identified the opportunity to mitigate high-emission sources like phasing out wet seal compressors to meet the industry trends.
Identify additional emission sources to focus on, such as pneumatics and flares.
The tool’s comprehensive data validation and benchmarking capabilities also enabled the client to plan for potential methane tax implications, implement reductions, and adapt operations as regulations evolved.

Overall, Montrose’s solution helped the client enhance environmental performance, achieve regulatory compliance, and improve operational efficiency.

Takeaways and Next Steps

Montrose’s BI tool is a versatile solution making it applicable for:

Diverse Regulatory Compliance Needs: The tool’s validation and data visualization capabilities make it an invaluable asset for clients in different sectors seeking to ensure compliance with various regulatory requirements.
Enhanced Data Management: Organizations dealing with large volumes of data and complex reporting requirements can leverage the tool to streamline data validation processes, improve accuracy, and reduce the need for resubmissions. The tool is scalable, allowing it to support small, medium, and large operations effectively.
Benchmarking and Performance Improvement: The tool’s benchmarking capabilities enable clients to compare their performance against industry standards and competitors. This is beneficial for enhancing operational efficiency, identifying areas for improvement, and aligning with industry trends.
Strategic Planning and Risk Management: By providing insights into emission sources and forecasting potential impacts of regulatory changes, the tool supports proactive planning and risk management. Clients can leverage the tool to anticipate future regulatory impacts and adjust their operational strategies accordingly.

The tool can be customized to meet the unique needs of various clients, helping them achieve compliance, improve data management, and enhance operational performance across different sectors.