(WO) – The American Petroleum Institute urged the Biden administration to revise the proposed Subpart W greenhouse gas (GHG) reporting rule so that it reflects the progress industry has made to reduce emissions, increases transparency and accuracy of reporting, and incentivizes innovations in the use of empirical data and cost-effective methane detection technologies.
In comments submitted to the U.S. Environmental Protection Agency (EPA) on the proposed “Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems,” API joined with the American Exploration & Production Council, Independent Petroleum Association of America, the Petroleum Alliance of Oklahoma, and the American Fuel and Petrochemical Manufacturers in expressing concern that several components of the rule as proposed could create undue cost burdens on producers and create regulatory incoherence with related regulatory efforts to reduce methane emissions.
The associations also reiterated their support for a cost-effective, technically feasible final rule and proposed solutions to improve many of the methodologies in the proposed rule.
“Since its inception, the oil and natural gas industry has participated as key collaborative stakeholders advancing the EPA Greenhouse Gas Reporting Program (GHGRP) by contributing expertise and proposing methodologies that reflect the reality of the industry and its evolving day-to-day operating practices,” said API Vice President of Corporate Policy Aaron Padilla. “We strongly support an accurate GHG emissions reporting framework, though we are also concerned that several aspects of EPA’s approach with this proposed rulemaking could ultimately hinder innovation and impose high implementation burdens without the same level of added value for the public.”
The comment letter identifies several areas of concern within the proposed rules and provides recommendations that allow the industry to continue to reduce GHG emissions cost effectively and increase transparency and accuracy.
Proposed solutions include:
allowing for the optional use of measured data in addition to EPA or company developed emission factors.
maintaining consistency with other EPA emissions rulemakings to avoid conflicting requirements.
offering more feasible alternatives for sources when proposed changes would impose high implementation burdens for small accuracy improvements.
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