Regulatory Submissions

AGA and APGA’s Comments on “Greenhouse Gas Reporting Rule: Revisions and  Confidentiality Determinations for Petroleum and Natural Gas Systems,” Docket ID No. EPA-HQ-OAR-2023-0234

APGA, jointly with the American Gas Association (AGA), filed comments on October 2 to the Environmental Protection Agency's (EPA) “Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems.” Both associations supported the EPA’s proposal to allow the development of site-specific emission factors and emissions reporting based on direct measurement. The comments encourage the EPA to provide an option for utilities to develop their own emission factors and recommend that the options for direct measurement be expanded to include more measurement technologies to provide greater flexibility for operators and would incentivize the use of new technologies and thus would result in reduction of methane emissions. APGA was also pleased to see the EPA’s utilization of the 2015 Lamb study (Direct Measurements Show Decreasing Methane Emissions from natural Gas Local Distribution Systems in the United States) for justification or their newly proposed emission factors.