Verified Gas Supply Across the LDC and IOU Footprint

For Local Distribution Companies, investor-owned gas utilities, electric utilities with material gas portfolios, and the sustainability and regulatory affairs teams running the methane and gas-supply decarbonization workload, the operating environment in 2026 is more demanding than any prior year. State methane rules are tightening — Colorado, New Mexico, California, New York — federal EPA Subpart W reporting has expanded, PUC rate-case proceedings now routinely include climate disclosure expectations, and downstream industrial and commercial gas customers are increasingly asking the LDC for fuel-attribute documentation that survives Scope 3 audit review. Utility natural gas emissions tracking and LDC methane reporting are no longer back-office workflows; they are operational requirements with regulator, ratepayer, and customer-side stakeholders watching how the documentation holds up.

Greentruth supports the utility on two fronts. Upstream — ISO 14064-3 reasonable-assurance verification of producer and operator primary data via the QET-NG methodology, aligned to NGSI Protocol v2.0, the OGCI Reporting Framework, ONE Future v6.2023, and OGMP 2.0 for EU-bound LNG corridors, with EPA Subpart W integration and state methane rule alignment for Colorado, New Mexico, California, and New York. Downstream — the GasTrace Scope 3 Category 3 EAC product, available free at the R&D GREET 2025 default tier, that the utility can offer to its industrial and commercial gas customers to substantiate their reporting under GHG Protocol Scope 3 and the customer-side frameworks they operate under (SBTi, CSRD, IFRS S2, SB 253, TCR).

For the upstream methodology

For the downstream product

Four forces are converging on the utility methane and gas-supply program in 2026:

• State methane and leak-detection rules. Colorado Regulation 7, New Mexico's natural gas waste and methane rules, California's SB 1383 and CARB methane rules, and New York's CLCPA all impose state-level methane reporting and reduction obligations. For LDCs with operations across multiple jurisdictions, the parallel reporting workload has become non-trivial.
• Federal EPA Subpart W expansion. EPA's Greenhouse Gas Reporting Program Subpart W has expanded coverage of methane emissions from natural gas systems, with reporting expectations that increasingly require source-specific direct measurement rather than industry-average estimation.
• PUC rate-case climate disclosure. Public Utility Commission rate-case proceedings now routinely include climate-related disclosure requirements — fuel-mix decarbonization plans, methane reduction commitments, ratepayer-funded clean-gas procurement programs.
• Customer-side Scope 3 pressure. Industrial and commercial gas customers — manufacturers, hospitals, universities, data centers, large commercial buildings — are increasingly asking their LDC or IOU for primary-data Scope 3 Category 3 documentation under GHG Protocol. The customer-side ask drives utility-side documentation requirements.

The combined effect: a utility methane and gas-supply program that survived 2023 review cycles is not automatically surviving 2026 cycles. The integrity threshold has risen on every front, and the documentation discipline has to rise with it.

For the MRV pillar overview

The utility population this page serves splits across three primary segments:

Local Distribution Companies (LDCs)

Gas-only operators running the distribution system between transmission interconnects and the end-use meter. LDCs typically purchase gas from upstream marketers and producers, blend across multiple supply sources, and serve a customer base that runs from residential through industrial. Their procurement teams care about fuel-attribute documentation that satisfies multi-jurisdiction reporting, supports rate-case proceedings, and gives the commercial and industrial customer base the Scope 3 documentation they are increasingly asking for.

Investor-Owned Gas Utilities (IOUs)

Often vertically integrated, holding interests in production, gathering, transmission, and distribution. IOU sustainability and regulatory affairs teams operate across the full value chain — their MRV and procurement documentation has to satisfy upstream operator reporting, midstream transmission disclosure, distribution-system methane reporting, and end-customer Scope 3 documentation simultaneously.

Electric Companies with Material Gas Portfolios

Electric power providers that operate gas-fired generation as a meaningful share of their fleet. They handle gas procurement at the wholesale level, and the methane intensity of the procured gas feeds directly into their generation Scope 1 disclosure through the Scope 3 Category 3 upstream-fuel pathway. For operators running renewable-electricity programs alongside material gas generation, the gas-side MRV is the often-overlooked piece of the corporate net-zero pathway.

Across all three segments, the integrity question is the same: can the fuel-attribute and methane-emissions documentation survive PUC review, regulator audit, ratepayer-advocate scrutiny, and customer-side Scope 3 verification at the level the relevant regime expects?

For the broader marketplace context

Utilities are unusual among Greentruth customers in that they sit at the middle of the value chain. They buy gas from upstream producers and sell it to downstream customers, and the documentation flowing through them has to satisfy both sides simultaneously.

Front 1 — Upstream MRV

ISO 14064-3 reasonable-assurance verification of producer and operator primary data flowing into the procurement program. The QET-NG methodology runs against the producer's primary MRV stack — continuous monitoring, segment-level OGMP 2.0 reporting where applicable, EPA Subpart W data, NGSI v2.0 / OGCI / ONE Future v6.2023 reporting — an accredited ISO 14065:2020 verifier signs off, and the resulting QET-NG is minted on the EarnDLT registry with the verified attributes attached.

Front 2 — Downstream Scope 3 Cat 3 EAC for the Customer Base

The same upstream-verified data flows downstream through GasTrace — the Scope 3 Category 3 EAC product the LDC or IOU can offer to its industrial and commercial gas customers. GasTrace is free at the R&D GREET 2025 default tier; customers receive registry-grade Scope 3 documentation without a separate procurement budget.

The two fronts solve different problems for different audiences but operate on the same data plane. A single upstream verification cycle produces outputs for the operator's own MRV reporting, the customer-side Scope 3 documentation, and the PUC rate-case disclosure — without three parallel paperwork workflows.

For the upstream methodology

For the downstream GasTrace product

The upstream side of the workflow is where most of the heavy lifting happens. The procurement program ingests producer and operator primary data through the QET-NG methodology with three integrity layers:

• Primary-data preference under the four-tier data-quality hierarchy. Site-specific primary data is preferred over process-specific primary, peer-reviewed secondary, or industry-average secondary data. The hierarchy is captured on every minted QET-NG.
• ISO 14064-3 reasonable-assurance verification. No data flows downstream without independent third-party verification. An accredited ISO 14065:2020 verifier reviews the producer's primary MRV stack, the methodology application, the uncertainty quantification, and the materiality threshold, and issues an unmodified verification opinion under ISO 14064-3 reasonable assurance.
• Framework alignment. The methodology runs against NGSI Protocol v2.0, the OGCI Reporting Framework, and ONE Future v6.2023 for US framework alignment; OGMP 2.0 Levels 4-5 + EEMDL Protocol for EU compliance extension where the operator serves EU-bound LNG corridors. EPA Subpart W data feeds the same methodology where the producer is a Subpart W reporter.

For the procurement team, a single QET-NG-anchored cycle produces outputs valid for the operator's own MRV disclosure, the customer-side Scope 3 Cat 3 documentation, PUC rate-case filings, and state methane rule reporting — all from the same primary-data ingestion and verification cycle.

For the data-quality hierarchy in detail · For the pipeline-level pathway

The downstream side is where the operator creates the most direct value for its customer base. GasTrace is the Scope 3 Category 3 EAC product offered free at the R&D GREET 2025 default tier — meaning every industrial and commercial gas customer of an LDC on Greentruth can receive registry-grade Scope 3 documentation without paying for the disclosure tier separately.

• Verified Scope 3 Category 3 disclosure. Replacing the customer's default upstream emission factor with the supplier-specific verified producer-level methane intensity. The customer's Scope 3 line improves from generic factor to primary-data quality.
• Machine-readable and human-readable retirement records. The customer-side disclosure cycle consumes the retirement record through the Machine-Ready API (for ESG software integration) and through downloadable retirement certificates (for human audit review).
• Framework-aligned exports. GHG Protocol Scope 3 Category 3, SBTi, CSRD ESRS E1, IFRS S2, SB 253, and TCR formats produced as machine-readable payloads — the same retirement event populates every framework's disclosure line simultaneously.
• Free at the GREET default tier. The base disclosure tier is no-cost to the customer. Where the upstream gas carries higher-tier primary data, the customer-side documentation reflects the higher tier.

For the full GasTrace product

For US natural-gas reporting, three industry framework anchors have converged on what producer-level methane reporting looks like in practice. The QET-NG methodology aligns to all three.

NGSI Protocol v2.0 (Natural Gas Sustainability Initiative)

NGSI v2.0 is the primary methodological backbone for producer-level methane intensity reporting in the US natural gas market. It establishes calculation conventions, system boundaries, and data-quality expectations. For utilities procuring from NGSI-aligned producers, the documentation that flows through QET-NG aligns directly to the framework.

OGCI Reporting Framework (Oil and Gas Climate Initiative)

The OGCI Reporting Framework provides cross-company methane and CO₂ reporting conventions that align large producer programs. Utilities procuring from OGCI member producers benefit from the cross-company comparability the framework enables.

ONE Future v6.2023 (Our Nation's Energy Future Coalition)

ONE Future is the cross-segment methane intensity reduction coalition whose v6.2023 reporting requirements apply to participants reporting facility-level and entity-level data. Utilities participating in ONE Future, or procuring from ONE Future participants, benefit from the structured cross-segment reporting and target architecture.

The QET-NG methodology operates as the integration surface across all three frameworks. A utility's procurement program can specify supplier preferences based on framework participation — the Discovery interface filters available QET-NG inventory accordingly, and the retirement record carries the framework participation metadata.

For OGMP 2.0 specifically

Federal and state methane reporting create the regulatory floor the utility procurement program operates over.

EPA Greenhouse Gas Reporting Program Subpart W

Federal Subpart W reporting covers methane emissions from petroleum and natural gas systems, with reporting expectations that increasingly require source-specific direct measurement. The QET-NG methodology integrates Subpart W data as one of the qualifying entity-level data sources under the Tier 2 CI determination.

State-Level Rules: Colorado, New Mexico, California, New York

• Colorado Regulation 7. Source-specific reporting and reduction requirements on operators in the state. LDCs and IOUs with Colorado operations have direct exposure.
• New Mexico natural gas waste and methane rules. NMED and EMNRD jointly administer the most operationally significant state-level methane regime outside California, with leak-detection-and-repair requirements and source-attributed reporting.
• California SB 1383 and CARB methane rules. California's short-lived climate pollutant strategy imposes reporting and reduction requirements. SB 253 layers on top for utilities above the $1B revenue threshold.
• New York Climate Leadership and Community Protection Act. New York's CLCPA imposes statewide methane reduction targets and disclosure expectations that propagate into utility reporting.

For utilities operating across multiple state jurisdictions, a single QET-NG-anchored verification cycle produces outputs valid for Subpart W reporting, multi-state methane rule reporting, and cross-state customer-side Scope 3 documentation — rather than parallel paperwork stacks per jurisdiction.

For CA-specific compliance

For utilities serving LNG export corridors — utilities that own or operate transmission interconnects feeding into LNG export terminals, or that procure gas destined for EU-bound cargoes — the EU compliance extension applies. The QET-NG methodology operates with additional alignment to OGMP 2.0 Levels 4-5 and the EEMDL Protocol, producing documentation that satisfies the EU Methane Regulation's Article 28 chain-of-custody and Article 8 reasonable-assurance verification requirements.

A single upstream verification cycle produces US-domestic documentation for NGSI v2.0 / OGCI / ONE Future reporting and EU compliance documentation under OGMP 2.0 + EEMDL Protocol for LNG cargo Article 28 submissions. The same QET-NG mint serves both lanes — no parallel verification cycles required.

For EU Methane Regulation compliance

Public Utility Commission proceedings have become an increasingly significant venue for climate-related disclosure expectations. Rate-case filings, integrated resource plans, gas-procurement plans, and decarbonization pathway plans all increasingly require structured documentation of methane reduction commitments, cleaner-gas procurement programs, and ratepayer-funded clean-energy investments.

• Procurement-program narrative. The utility can demonstrate that its gas-supply procurement has shifted toward verified low-CI suppliers, with ISO 14064-3 reasonable-assurance verification and documented framework alignment (NGSI v2.0, OGCI, ONE Future v6.2023). The shift is documentable in PUC filings rather than asserted narratively.
• Customer-side benefit articulation. The free GasTrace Scope 3 Cat 3 EAC available to commercial and industrial customers is a tangible ratepayer-side benefit — the utility's procurement decisions create downstream Scope 3 disclosure value for the customer base, not just abstract methane reduction at the producer end.
• Decarbonization roadmap alignment. The QET-NG framework integrates with broader corporate decarbonization expectations under the SBTi Corporate Net-Zero Standard and CSRD ESRS E1, which utilities and their parent IOUs are increasingly committing to.

For the broader Net Zero Decarbonization framing