Regulatory Submissions

In February, APGA provided comments on the Environmental Protection Agency’s (EPA) proposed standards for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources within the oil and natural gas sectors. APGA is concerned that EPA’s proposal will lead to cost-ineffective and legally unsound regulatory standards for facilities that extract and transport natural gas to America’s public gas utilities. APGA urges EPA to ensure that new regulations do not have downstream impacts, such as higher energy costs.  

In the feedback provided, APGA expressed concern with the Super-Emitter Response Program (SERP), which seemingly will impose stringent obligations by unregulated third-party entities. Public natural gas systems support the goal of decreasing super-emitter events through proper oversight. However, the final SERP should not simply grant authority to random third-party individuals or entities.  

APGA also opposes mandatory, prescriptive leak detection requirements, as this action will disincentivize new technologies. EPA should allow flexibility when it comes to the technologies and the techniques used by the industry for leak detection.  

In addition to this input, APGA stated support for the technical feedback of the American Petroleum Institute (API) and the U.S. Chamber of Commerce. This proceeding was an opportunity to collaborate with these like-minded stakeholders to ensure the value of natural gas is known to policymakers.