AGA Comments Support Updated GHGI Emission Factors for LNG Storage and Import/Export Facilities

In comments  filed November 16, 2018, AGA supported EPA’s proposal to update the emission factors (EFs) used to estimate methane and  CO2 emissions from LNG storage facilities and LNG import/export facilities in the GHGI.  Currently, the GHGI relies on EFs based on the 1996 GRI/EPA study to estimate LNG storage and LNG import terminal methane and CO2 emissions.  Because specific emissions data for LNG storage stations and import terminals was not available, these EFs were developed based on underground natural gas storage and transmission compressor station data.  EPA is considering, and AGA supports, improving the methodology used to estimate annual average methane and CO2 emissions from LNG facilities by developing EFs based on actual emissions data reported under Subpart W for LNG storage (peak shaving) facilities and LNG import and export terminals.  By incorporating data reported under Subpart W, GHGI emissions estimates will more accurately reflect the current state of operations at LNG storage and LNG import/export facilities.  Additionally, AGA supported updating emissions data for LNG operations annually to better account for the dynamic trends in the LNG sector.   AGA commends EPA’s efforts to improve the accuracy of the data in the GHGI.  As the quality of the data in the GHGI continues to improve, industry, the public, and policymakers will be better able to understand natural gas methane emissions and the important role natural gas plays in reducing greenhouse gas emissions.