AGA Asks EPA To Clarify Pipeline Blow Down Greenhouse Gas Reporting
On Feb. 24, 2015, AGA filed comments on EPA’s Dec. 9, 2014 proposed rule. EPA proposed to revise the “Subpart W” rules to expand the universe of oil and natural gas sources required to report carbon dioxide and methane emissions. Most of the new provisions are focused on upstream production; for example, EPA proposed to require producers to report natural gas emissions vented or flared from hydraulically fractured oil wells. EPA also proposed to require operators of interstate natural gas transmission pipelines – and certain types of intrastate transmission pipelines - to report methane emissions from pipeline blow downs performed as a safety measure prior to repair or replacement. Most intrastate pipelines would not be subject to the new reporting rule, but it is not clear where to draw the line. AGA asked EPA to clarify that intrastate pipelines are exempt if they provide no interstate service or only a de minimis amount and do not have a FERC-filed Statement of Operating Conditions under section 311 of the Natural Gas Policy Act.
INGAA filed comments seeking clarification on a variety of proposed reporting requirements for interstate transmission and storage. With respect to intrastate lines, INGAA said they did not understand why EPA is requiring blow down reporting for interstate lines but not intrastate lines. INGAA also asked EPA for clarification.