Q289. How should

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a Local Distribution Company (LDC) determine if it "delivers" more than 460,000 thousand standard cubic feet (Mscf) per year? Does this include quantities delivered to other LDCs and or large end-users? What about natural gas placed into or removed from storage?

A289. According to Table A-5 of Part 98 (Subpart A), local natural gas distribution companies LDCs that deliver 460,000 000 thousand standard cubic feet (Mscf) or more of natural gas per year are subject to the rule40 CFR part 98, subpart NN. This threshold does not include includes deliveries to all end-users, including deliveries of gas not owned by the LDC and deliveries of gas to end-users that receive greater than 460,000 Mscf per year. Gas deliveries to other LDCs or downstream gas transmission pipelines are excluded as they are not deemed "end-users". This threshold does cover deliveries to all end users, including those end-users that receive greater than We recommend you use one of the following two approaches to determine whether your LDC exceeds the 460,000 Mscf per year.There are two potential ways that an LDC could calculate whether they surpass the threshold. One option is to add the appropriate delivered volumes of natural gas in 98.406. To determine natural gas "delivered" from the data elements in 98.406 you would take the annual volume in Mscf received by the LDC, subtract the volume placed into storage, add threshold.

Option 1:  Sum the following parameters:

1. Annual volume of natural gas received by the LDC that passed through the city gate(s);
2. Annual volume of natural gas received by the LDC that did not pass through a city gate (e.g., gas delivered directly to LDCs from producers or gas processing plants);
3. Annual volume of natural gas withdrawn from on-system storage, including vaporized LNG produced at on-system vaporization facilities for delivery,

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1. that is not

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1. included in items 1 or 2 above.

From the total, subtract the following:

• Annual volume of natural gas placed into storage,
• Annual volume of natural gas re-delivered to downstream gas transmission pipelines and other LDCs.

Option 2: Use the equations in 40 CFR 98.403(a) and (b) to calculate the CO₂ emissions that would result from the combustion of gas supplied using Equations NN-4 and NN-6. Next, sum the values calculated using Equations NN-4 and NN-6. Divide the resulting total by the CO₂ emission factor for natural gas to convert from metric tons of CO₂ to volume of natural gas in Mscf. Use the default CO₂ emissions factor from Table NN-2 (0.0544 metric tons CO₂e per Mscf as of January 2018) or a reporter-specific CO₂ emissions factor, if you developed your own CO₂ emission factor and used it to calculate the CO₂ emissions.

  local distribution companies. In summary, total gas delivered would be (b)(1)- (b)(2) + (b)(3) + (b)(4) + (b)(5) - (b)(6).Alternatively, you could add the emissions calculated using Equation NN-6 and the emissions calculated using Equation NN-4. Please note, however, that the threshold for subpart NN is in terms of Mscf, so you would need to convert the GHG emissions estimate in metric tons back to Mscf to determine applicability.

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Source: This question and answer was derived from a Legacy FAQ (updated for post-RY2010 reporting by B. Cook, 1/12/2013), updated by B Cook n 1/12/18

Approval / Publishing History: Version 2 (Approved by L. Grogan-McCulloch, 1/14/2013), Version 3 (Approved by B. Cook, 1/xx/2018)

Expiration: None

Relevant Subparts:  Subpart NN

Note to Self: Old URL - Q289. How should an LDC determine if it "delivers" more than 460,000 Mscf per year? Does this include quantities delivered to other LDCs and or large end-users? What about natural gas placed into or removed from storage?
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