AGA Urges EPA Not to Incorporate Flawed Leak Survey Requirements Into GHG Reporting Program

Policy March 18, 2016

On March 15, 2016, AGA provided feedback to EPA on the Agency's proposed revisions to the petroleum natural gas systems source category (Subpart W) of the Greenhouse Gas Reporting Program. Atlthough AGA generally supports the incorporation of new methodologies into the GHGRP that have the effect of providing sources with flexibility in reporting, AGA enouraged EPA not to incorporate into Subpart W the leak survey methods proposed in the New Source Performance Standard (NSPS) Subpart OOOOa for the oil and gas industry. AGA highlighted the numerous deficiencies and and flaws with the proposed leak surveys that would need to be addressed prior to any incorporation into Subpart W. AGA encouraged EPA to withdraw the Subpart W Proposed Rule and reconsider whether any revisions are necessary once the final NSPS is in effect. A link to AGA's comments is below.

AttachmentSize
AGA Comments on Proposed Subpart W Revisions764.88 KB