detection technologies . In comments submitted to the EPA on the proposed “ Greenhouse Gas Reporting Rule : Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems ,” API joined with the American Exploration & Production Council , Independent Petroleum Association of America , the Petroleum Alliance of Oklahoma , and the American Fuel and Petrochemical Manufacturers in expressing concern that several components of the rule as proposed could create undue cost burdens on producers and create regulatory incoherence with related regulatory efforts to reduce methane emissions . The associations also reiterated their support for a cost-effective , technically feasible final rule and proposed solutions to improve many of the methodologies in the proposed rule .

“ Since its inception , the oil and natural gas industry has participated as key collaborative stakeholders advancing the EPA Greenhouse Gas Reporting Program ( GHGRP ) by contributing expertise and proposing methodologies that reflect the reality of the industry and its evolving day-to-day operating practices ,” said Padilla , API ’ s vice president of corporate policy . “ We strongly support an accurate GHG emissions reporting framework , though we are also concerned that several aspects of EPA ’ s approach with this proposed rulemaking could ultimately hinder innovation and impose high implementation burdens without the same level of added value for the public .”

The comment letter identifies several areas of concern within the proposed rules and provides recommendations that allow industry to continue to reduce GHG emissions cost effectively and increase transparency and accuracy . Proposed solutions include allowing for the optional use of measured data in addition to EPA or company developed emission factors ; maintaining consistency with other EPA emissions rule-

makings to avoid conflicting requirements ; and offering more feasible alternatives for sources when proposed changes would impose high implementation burdens for small accuracy improvements .

Revisions to EPA ’ s Greenhouse Gas Reporting Program authorized by Congress will bring greater transparency and accountability for methane emissions from oil and natural gas facilities , one of the major drivers of climate change , the administration said in its May 6 announcement of the final rule .

The final rule to strengthen , expand , and update methane emissions reporting requirements for petroleum and natural gas systems under EPA ’ s Greenhouse Gas Reporting Program was required by President Biden ’ s Inflation Reduction Act . The final revisions will ensure greater transparency and accountability for methane pollution from oil and natural gas facilities by improving the accuracy of annual emissions reporting from these operations , the administration said .

“ Oil and natural gas facilities are the nation ’ s largest industrial source of methane , a climate ‘ super pollutant ’ that is many times more potent than carbon dioxide and is responsible for approximately one third of the warming from greenhouse gases occurring today ,” according to the statement .

Continued on pg . 30

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