New Mexico GHG Management regulations & environmental compliance analysis

New Mexico GHG Management: What you need to know

Governing Law and Regulations

Reporting greenhouse gas (GHG) emissions:

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Mandatory reporting: 40 CFR 98 and 20.2.73 NMAC

GHG Permitting: 20.2.74 NMAC and 20.2.70 NMAC

GHG reduction targets: Executive Order (E.O). 2019-003

Other Climate Change Initiatives: E.O. 2019-003 and S.B. 489 (2019)

Regulatory Agencies

New Mexico Environment Department (NMED)

Air Quality Bureau (AQB)

Energy, Minerals, and Natural Resources Department (EMNRD)

Comparison: State vs. Federal

Rules. Applicable sources must comply with the federal greenhouse gas (GHG) reporting program under 40 CFR 98. New Mexico has additional mandatory GHG reporting for Title V sources and encourages voluntary reporting. New Mexico has established targets to reduce GHG emissions in the state.

Administration and enforcement. NMED administers the state's climate change programs to address GHG emissions and coordinates with other states to assist in the implementation of regional climate change initiatives.

State Requirements


Mandatory Reporting

40 CFR 98 and 20.2.73 NMAC

Applicability. The NMED requires emissions inventories (EI) from permitted major sources, excluding facilities in Bernalillo County and on Tribal Lands. Mandatory reporting of GHG emissions from Title V sources is required as follows.

  • Oil and gas operations must report carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O) emissions from stationary combustion sources
  • Oil and gas operations must report CO2 and CH4 fugitive emissions (i.e., vented and equipment leak emissions).
  • Non-oil and gas operations must report CO2 and CH4 emissions

General reporting requirements. Applicable sources must monitor GHG emissions and submit emissions reports to the NMED. The NMED will accept GHG ...

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