AGA Files Comments on EPA Subpart W Methane Reporting Rule Proposed Revisions
AGA together with APGA filed detailed joint comments on Oct. 6, 2022 on EPA’s proposed rule to revise the greenhouse gas (GHG) reporting rules in 40 CF.R. Part 98, including the Subpart W methane reporting rules. The AGA draft comments focus on five key issues for natural gas distribution. We ask EPA: (1) to postpone finalizing the Subpart W portion of the GHG Reporting Rule proposed revisions and to conduct a single rulemaking on Subpart W that incorporates changes Congress required EPA to make in Subpart W in the Inflation Reduction Act, enacted in August; (2) to allow more time to implement systems and procedures to collect the required data; (3) to reject using the Weller 2020 study based on its limitations, and instead use the Lamb 2015 WSU emission factors for mains and services, consistent with the EPA GHG Inventory; (4) to improve and expand the option for direct measurements and company-specific emission factors; (5) to allow an option to use advance mobile leak detection (AMLD) with robust data and multiple vehicle passes to improve accuracy; and (6) to urge PHMSA to accept AGA’s Petition for Reconsideration and remove an ambiguous phrase (“or other pipelines” from the definition of natural gas “transmission pipeline” — or if PHMSA fails to do so, to clarify EPA’s Subpart W definition of “distribution line” which relies on PHMSA’s definitions.
In addition, the AGA-APGA comments support INGAA’s comments requesting revisions to clarify and improve reporting rules for natural gas transmission compression, underground storage, LNG peak-shaving storage facilities, and LNG import-export terminals.
AGA also joined in multi-industry coalition comments submitted by the U.S. Chamber of Commerce regarding Subpart W and other subparts of the EPA greenhouse gas reporting rules.