Mar 15, 2016 Industry Trade Associations Joint Comments to the U.S. Environmental Protection Agency on its Greenhouse Gas Reporting Rule Leak Detection Methodology (Subpart W)
The following comments to the proposed Greenhouse Gas (GHG) Reporting Rule (Subpart W) changes released by the Environmental Protection Agency (EPA) on January 29, 2016, are submitted on behalf of Western Energy Alliance, the Independent Petroleum Association of America, and the American Exploration and Production Council. We appreciate the opportunity to provide EPA with comments on its proposed rule, and wish to express several concerns with EPA’s proposal. The timing of EPA’s proposal is troubling, given that industry cannot fully evaluate its impacts until EPA’s New Source Performance Standards (NSPS) Subpart OOOOa is finalized. This problem is compounded by the Bureau of Land Management’s (BLM) recently proposed rule addressing venting and flaring, as there is potential for significant overlap in leak detection and repair (LDAR) protocols. Should EPA decide to move ahead with its proposed changes despite these concerns, we have several suggested revisions that will increase the accuracy and flexibility of the proposed rule.
