New Emission Monitoring Program for the Oil and Gas Sector

Through Resolution 258/2025, published in the Official Gazette of the Province of Neuquen on April 1, 2025, the Secretariat of Environment of the Province of Neuquen created the Greenhouse Gas Emission Monitoring and Mitigation Program for the Oil and Gas Sector. The Program aims to detect, quantify, control, and verify greenhouse gas (GHG) emissions—specifically methane, carbon dioxide, and nitrous oxide—generated by these obligated entities: any company or group of companies, concessionaires, permit holders, or operators, regardless of their legal form, whether domestic or foreign, or joint ventures, engaged in exploration, exploitation, transportation, storage, processing, and industrialization of hydrocarbons in the Province of Neuquen.

Entities carrying out such activities must report their GHG emissions, activity data, mitigation measures, and any additional information necessary for quantifying emissions or related to mitigation measures, as determined by the Secretariat in its capacity of enforcement authority. For this purpose, the program established these specific objectives:
 

1. implementing a unified GHG emission reporting system for entities in the Oil and Gas sector,
2. establishing a baseline for emissions in Neuquen,
3. developing mechanisms for data collection,
4. promoting the adoption of best practices,
5. fostering transparency and public participation.

The program is structured in two phases: a pilot phase and an implementation phase.
 

1. Pilot Phase

This phase will last one year as of the creation of the program. Its objective is to develop a reporting procedure for the obligated entities and a Sectoral Mitigation Plan, based on an initial sectoral assessment and consultations conducted by a working group composed of relevant stakeholders.

During this phase, obligated entities must respond to an initial information request that will include—among others—identifying sectoral focal points, strategies and policies related to emissions monitoring, methodologies and tools used, as well as data on annual emissions and intensity indicators. This phase will also review the level of compliance with international regulations, internal capabilities, and mitigation actions planned or implemented. The Secretariat may require additional information.

Based on the results, a schedule will be established for developing the reporting procedure, and a sectoral working group will be formed to serve as a consultation space.

Obligated entities must submit a preliminary report, prepared in accordance with the reporting procedure, to assess its initial implementation, make any necessary amendments, and serve as input to the develop of the Sectoral Mitigation Plan. The Secretariat will review and approve the report.

The final version of the reporting procedure for obligated entities must be published within 12 months of the program’s effective date. This procedure will establish the guidelines and requirements for the Annual Emissions Report and include:

1. Methodology, timeline, formatting, and tools for emissions reporting.
2. A specific section on methane emissions, with specific guidelines for monitoring, quantifying, verifying, and mitigating them.
3. Segmentation of the type and level of reporting, according to the obligated entities’ capacity and classification of their facilities.
4. A mechanism for continuous review and adjustment of the procedure to ensure regulatory alignment and continuous improvement.

The Secretariat must prepare and publish a Sectoral Mitigation Plan for the hydrocarbon sector at the provincial level, which will serve as input for the development of the Provincial Climate Action Plan. It will also establish the minimum components that must be included in the mitigation plans the obligated entities must submit.
 

2. Implementation Phase

This phase will start once the pilot phase is complete. In this phase, obligated entities must submit an Emissions Report prepared in accordance with the reporting procedure and validated by authorized third parties. The Secretariat will review and approve this report.

Obligated entities must also submit a Mitigation Plan aligned with both the objectives of the Sectoral Mitigation Plan and their corresponding Annual Emissions Report. The Secretariat will determine the contents, deadlines for submission and update; and the compliance reports’ format and frequency.

The results of the reports and mitigation plans will be published, ensuring access to public information without compromising data confidentiality.
 

3. Verification and Inspection

To ensure the reported information and compliance with the commitments undertaken are reliable, the Secretariat may request measurements and/or verifications through random inspections, external audits, or the involvement of independent third parties. Any inconsistencies or repeated and unjustified non-compliance could lead to sanctions pursuant to the procedures established by applicable regulations.

The Undersecretariat for Climate Change may issue any necessary regulatory provision for the effective implementation of the program.