May. 16, 2022
May 16, 2022 I am not sure that this comment fits in with your request for comment, but I think it is most important in the way in which initial GHG metrics are carried out and GHG volumes calculated. This comment applies specifically to upstream hydrocarbon production (i.e. when GHG first come out of the ground). Oil companies can calculate precisely how much methane comes out of a well. In many cases they seem not to want to do this. They accurately measure the volume of oil coming from a well. This is their business. In addition, they also accurately measure the GOR (Gas/Oil Ratio) by taking a live oil sample and analyzing it in a chemical laboratory. This GOR is a characteristic of the crude oil that exists within a reservoir or series of fractures. It is typically specific to a particular reservoir or pool of oil and does not change over a period of time. If X barrels of oil have been produced then Y mmscf of GHG will have been released associated with this oil (and calculable based on the GOR). If double the amount of oil is produced, double the amount of GHG (2Y) will also have been produced. The produced GHG will have a characteristic make up (% methane etc). This approach can then define how much GHG comes out of the well and its composition. What happens to this CHG can then be analyzed and disclosed. Effectively this is a simple Mass Balance approach to measuring the amount of GHG. Once this approach is taken a true assessment of a companys GHG emissions can be made, such that full disclosure can occur to shareholders and the financial markets in general. I have not seen a mass balance approach noted in this respect, I am surprised.