IOGP Europe response to DG ENVI and Trinomics survey on assessment of environmental reporting and the potential for simplification

This document outlines IOGP Europe’s contribution to the European Commission’s assessment of environmental reporting obligations, led by DG Environment in collaboration with Trinomics. It presents our members perspective on the Industrial Emissions Portal Regulation (IEP-R), highlighting key areas where simplification, proportionality, and better alignment with existing frameworks are essential. Drawing on input from member companies, this document sets out concrete recommendations to improve the effectiveness and efficiency of environmental reporting while maintaining high standards of environmental protection and transparency. 

6 key recommendations: 

1.  Introduce a Capacity Threshold

Problem: All oil and gas installations must report under IEP-R, even those with negligible emissions. 

Recommendation: Add a capacity threshold (e.g., 500,000 m³/day of gas or 500 tonnes/day of crude oil) to focus reporting on installations with real environmental impact.

2.  Shift Reporting Level from Installation to Facility

Problem: Reporting at the installation level creates excessive granularity (e.g., one facility could mean 200+ installation reports). 

Recommendation: Allow reporting at the facility level for upstream oil and gas to reduce administrative burden and better reflect actual environmental impact.

3. Improve Proportionality & Simplify Reporting

Problem: Detailed reporting from small sources adds cost without environmental value. 

Recommendations: 

• Standardize pollutant lists and templates across Member States. 
• Automate data collection and simplify reporting processes. 
• Request data only when truly needed for environmental policy.

4. Avoid Duplication with Existing Regulations

Problem: Overlaps with OSPAR, MCPD, Urban Waste Water Directive, etc. 

Recommendations: 

• Harmonize IEP-R with existing frameworks. 
• Define clear criteria for additional data requests. 
• Make IEP-R the central reporting hub.

5. Protect Confidential Business Information

Problem: Requirement to publish certain permit documents could expose commercially sensitive data.

Recommendation: Limit reporting to relevant environmental information and redact sensitive business data.

6. Allow Flexible Data Collection Methods

Problem: IEP-R prioritizes direct measurement, which is often costly and unnecessary. 

Recommendation: Accept estimation and calculation methods where appropriate to reduce costs and complexity. 

These six recommendations aim to ensure that the Industrial Emissions Portal Regulation can deliver meaningful environmental insights without placing disproportionate burdens on operators. By promoting a more efficient, proportional, and pragmatic approach to reporting, IOGP Europe believes the framework can better serve both environmental objectives and Europe’s broader energy and industrial priorities. We remain committed to working constructively with the European Commission and stakeholders to support smart regulation that enables transparency while preserving operational efficiency and energy resilience.

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