AGA Comments on EPA Subpart W Greenhouse Gas Confidential Business Information & Reporting Deferral Proposed Rule (April 9, 2012)
On Feb. 24, 2012, EPA proposed to delay the greenhouse gas reporting deadline from Sept. 2012 until March 2015 for methane emissions from several types of natural gas operations equipment. The reporting deferral is intended to give EPA time to determine whether such data qualifies for protection as confidential business information (CBI). Most of the proposed reporting deferrals relate to production facilities, but two relate to gas utilities. Based on input from our members, AGA told EPA no thanks to the proposal to postpone reporting the miles of pipe and the company-specific emission factor estimating methane leaks from pressure regulator stations. AGA members already report the number of miles of pipe by material type to the Department of Energy (DOE) Energy Information Administration (EIA) every year. This is public information and there is no reason not to go ahead and report that pipe mileage data to EPA also. We also told EPA that members see no need to defer reporting the company-specific emission factor calculated for above ground pressure regulator stations. We anticipate based on the 2011 leak survey results that this data will help demonstrate that methane leaks from these stations are much lower than EPA currently assumes. In addition, we support EPA s proposal not to postpone reporting the number of shale gas wells that capture methane in green well completions. This data will be especially helpful in reducing the estimated carbon footprint of the natural gas value chain.