AGA Files Comments on EPA’s August 2023 Proposed Revisions to Subpart W of Greenhouse Gas Reporting Rule

On October 2, 2023, AGA and the American Public Gas Association (“APGA”) jointly filed detailed comments on EPA’s August 2023 proposed rule to revise Subpart W of the Greenhouse Gas Reporting Program (“GHGRP”) regulations, which are codified at 40 C.F.R. Part 98. This is the latest in a series of comments that AGA has filed over the past year with regard to Subpart W and related regulatory actions under the Inflation Reduction Act of 2022.

AGA and APGA’s comments support EPA’s proposal to allow gas utilities to report emissions based on direct measurements, to not require the use of top-down methods, and to develop emission factors (“EFs”) based on leak study data that is more representative of distribution segment emissions than other study data EPA had proposed to use in an earlier GHGRP rulemaking. The comments also urge the agency to increase flexibility under Subpart W, including by allowing broader use of company-specific EFs and streamlining the approval process for using new methane detection and measurement technologies. The comments oppose EPA’s proposed use of upstream data to develop EFs or EF modifiers (e.g., a multiplier to account for undetected leaks) for downstream segments like natural gas distribution and pointed out areas where proposed reporting requirements are incompatible with distribution equipment.

AGA and APGA’s filing also expresses support for the comments submitted by the Interstate Natural Gas Association of America (“INGAA”) on the proposed rule with regard to natural gas transmission, storage, and LNG operations.