| Program | Authority | Status | Applies | Obligation Type |
|---|---|---|---|---|
| EPA Greenhouse Gas Reporting Program (GHGRP) | U.S. EPA | Effective | YES | Reporting-only (mandatory annual GHG reporting, monitoring, |
| EPA Section 111 NSPS — GHG Standards for New Gas Turbines | U.S. EPA | Partial Repeal | UNKNOWN | Performance standard (efficiency-based CO2 emission rate) |
| SEC Enhancement and Standardization of Climate-Related Disclosures | U.S. SEC | Stayed | UNKNOWN | Securities disclosure (GHG emissions, climate risks) |
| Texas State Climate/Carbon Programs | TCEQ / Texas Legislature | N/A | NO | None |
| ERCOT/Utility Climate-Related Pass-Through Charges | ERCOT / PUCT | N/A | NO | None |
| Adjustment | Condition | Status | Points | Evidence Summary |
|---|---|---|---|---|
| FIRST_BINDING_PROGRAM | At least one binding mandatory climate-compliance program applies directly | MET | +3 | EPA GHGRP reporting is a binding federal obligation. Facility emissions (~185,890 MT CO2/yr) far exceed 25,000 MT CO2e t |
| ADDITIONAL_BINDING_PROGRAMS | Additional distinct directly applicable binding programs beyond the first | UNMET | 0 | Section 111 NSPS applicability to BTM no-export facility is UNKNOWN (EGU definition requires selling to utility distribu |
| FINANCIAL_EXPOSURE | Financial exposure adjustment (max +3) | UNMET | 0 | GHGRP is a reporting-only obligation with no carbon charge or allowance purchase. Mandatory MRV implementation costs exi |
| PROPOSED_FORWARD_RISK | Proposed or adopted-not-effective program creating forward risk | MET | +1 | Section 111 NSPS: partial repeal finalized Sept 2026 (effective Nov 16, 2026) removed CCS-based standards; efficiency-ba |
| SUPPLIER_PASSTHROUGH | Gas/electricity supplier climate-related pass-through evidenced but unquantified | UNMET | 0 | No evidence of carbon or climate compliance charges in ERCOT electricity prices or Texas natural gas tariffs. Texas has |
| JURISDICTION_AMBIGUITY | Residual jurisdiction or service-territory ambiguity creating exposure uncertain | MET | +1 | Whether Section 111 NSPS applies to a BTM no-export facility remains unresolved. The 'affected EGU' definition requires |
| ALL_REPORTING_ONLY | All verified direct programs are reporting-only with no financial obligation | UNKNOWN | 0 | GHGRP is reporting-only (no carbon charge), but mandatory MRV implementation costs (monitoring equipment, data managemen |
| VERIFIED_EXEMPTION | Verified exemption, allocation, or exclusion under applicable program | UNMET | 0 | No verified exemptions applicable. GHGRP applies without exclusion. |
| Total Risk Score | 5 | MAX(0, sum of adjustments) | ||
The 50 MW net BTM gas-fired facility in Victoria County, TX triggers mandatory EPA GHGRP reporting (illustrative ~185,890 MT CO2/yr, well above the 25,000 MT threshold). Texas has no state carbon pricing or GHG reporting program. ERCOT operates no carbon market. The Section 111 NSPS applicability to a no-export BTM facility remains unresolved, and the rule is in active regulatory flux (partial repeal finalized Sept 2026, full rescission proposed). Mandatory MRV implementation costs are required but unquantified.
Cost Ledger: Total mandatory climate-compliance cost is null (unresolvable). Direct carbon charge subtotal: $0 (no carbon pricing applies in Texas/ERCOT). GHGRP mandatory monitoring, reporting, and verification costs are required but unquantified — per methodology, a required unquantified component makes total cost null. No supplier climate pass-through charges identified.
Regulatory Trajectory: The federal regulatory environment for GHG standards is in significant flux. EPA’s Section 111 carbon pollution standards for power plants were partially repealed in September 2026, with a supplemental proposal to rescind all remaining standards under public comment. The SEC climate disclosure rule has been stayed since April 2024 with proposed rescission in May 2026. Texas remains without state-level carbon pricing or GHG reporting. The primary binding obligation is EPA GHGRP annual emissions reporting.