AGA Comments on Four EPA Requests for Information (RFIs) on Inflation Reduction Act Climate Initiatives (Jan. 18, 2023)

On January 18, 2023, AGA filed comments on four EPA RFIs on how to implement provisions in the Inflation Reduction Act (August 2022) relating to reducing or reporting greenhouse gas (GHG) emissions.

  1. AGA Comments 1-18-2023 on State, Tribal and County Climate Grants: Responding to EPA’s RFI on grants to state, tribal and county governments to develop and implement GHG reduction plants, AGA urged EPA to take a diversified portfolio approach to include multiple technological pathways to achieve net-zero GHG goals, including hydrogen, renewable natural gas  (RNG), and innovative more efficient natural gas equipment such as high-efficiency furnaces and gas heat pumps. 
  1. AGA Comments 1-18-2023 on Methane Fee/ Methane Reduction Grants & Incentives in Oil and Natural Gas Sector: AGA urged EPA to revise its Subpart W methane reporting rule to allow company-specific measurements and emission factors to improve the accuracy of methane emissions reports used to assess performance and determine whether emissions exceed thresholds for imposing a methane “waste emissions charge” or methane fee.  With respect to methane reduction grants, AGA urged EPA to include opportunities for gas utilities to further their efforts to reduce methane emissions form gas distribution systems, including deployment of advanced leak detection and repairs, reducing blowdowns, and replacing more leak prone vintage pipe with modern polyethelene (PE) or protected steel pipe.
  1. AGA Comments1-18-2023 on Air & Methane Monitoring – Reconciling Top-Down and Bottom-Up Measurements:  In response to EPA’s question regarding differences between top-down (e.g., airplane, satellite) methane measurements and bottom-up (e.g., facility and equipment level) emissions, AGA pointed EPA to the landmark, peer-reviewed Fayetteville Basin Methane Reconciliation Study, which found that both measurements have validity but they differ in timing and spatial scale.  They can be reconciled by aligning them in the same timeframe and area.
  1. AGA Comments 1-18-2023 on GHG Corporate Reporting: AGA responded that EPA could provide the most value to corporate GHG target setting and tracking by improving its GHG reporting rules, particularly the Subpart W methane reporting rules, by allowing gas utilities and other reporters to use empirical data such as company-specific measurements and emission factors.