AGA Files March 14, 2019 Comments on EPA's Draft 2019 Greenhouse Gas Inventory
In a February 12, 2019 Federal Register notice (84 Fed. Reg. 3444), EPA requested comment on the 2019 draft GHGI report, which updates the emission factor for transmission pipeline blowdowns using the average from corrected 2016 data and 2017 data. The notice also requests feedback on whether year-specific emission factors should be applied for 2016 and 2017, and whether the current emission factors should be applied for earlier years of the time series.
AGA filed comments on March 14, 2019 noting that we appreciate EPA’s response to our November 2018 comments in using corrected rather than the originally flawed 2016 data and revising the emission factor that was initially proposed. While AGA continues to recommend waiting an additional year to integrate Subpart W data so that EPA can average the results from three years of reporting, we understand EPA’s desire to proceed with the updated emission factor and applaud efforts to utilize Subpart W results to improve emission estimates for natural gas operations.