On June 16, 2014, AGA submitted comments to the U.S. Environmental Protection Agency (EPA)'s Office of Air Quality Planning and Standards on the EPA technical white paper on "Oil and Natural Gas Sector Leaks," also known as the "Leaks Paper." This is one of five technical white papers that EPA released on April 15, 2014 for external peer review relating to “potentially significant sources of methane and volatile organic compounds (VOCs)” from the oil and natural gas sector – focusing on operations upstream of natural gas distribution systems. The five white papers evaluate emissions from: (1) production well completions; (2) production well liquids unloading; (3) compressors; (4) pneumatic devices; and (5) equipment leaks “upstream of natural gas distribution systems.”
Since AGA represents natural gas utility companies that operate local distribution systems, the white papers have limited direct applicability to our members’ core business. However, we are concerned that some of the broad assumptions made in the white papers, particularly in the Leaks Paper, are not valid with respect to distribution and could indirectly impact distribution operations. These comments seek to clarify the record and avoid later misunderstandings.