There’s still time to comment on one methane rule proposed by the EPA, which was partly prompted by outside comment to start with. So far, the only comments are by fossil fuel industry consortiums. Why should they have all the fun? Here’s how to post your own comments. And there may be another rule announced today.

Posted by the EPA, 9 December 2014, Greenhouse Gas Reporting: 2015 Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems,

The Environmental Protection Agency (EPA) is proposing revisions and confidentiality determinations for the petroleum and natural gas systems source category of the Greenhouse Gas Reporting Program. In particular, the EPA is proposing to add calculation methods and reporting requirements for greenhouse gas emissions from gathering and boosting facilities, completions and workovers of oil wells with hydraulic fracturing, and blowdowns of natural gas transmission pipelines between compressor stations. The EPA is also proposing well identification reporting requirements to improve the EPA’s ability to verify reported data and enhance transparency. This action also proposes confidentiality determinations for new data elements contained in these proposed amendments.

Pipelines between compressor stations would affect the compressor stations proposed for the Sabal Trail pipeline. The proposed rule also spells out in numerous places that it’s about distribution pipelines, too. And the proposed rule was partly motivated by requests from concerned parties:

Third, on March 19, 2013, the EPA received a petition from a group of non-government organizations (NGOs) asking that the EPA collect data from emissions sources not currently included in subpart W, including well completion emissions from oil wells that co-produce natural gas, facilities and pipelines in the gathering and boosting segment, and transmission pipeline blowdown events, because these sources could be significantsources of emissions that are not being reported. The NGOs also asked the EPA to require the reporting of API well identification numbers (currently known as US Well Numbers) to allow cross-reference to production data and other important information, to phase out the use of best available monitoring methods (BAMM), and to consider including “Advanced Innovative Monitoring Methods” to “accelerate development and deployment of real-time continuous methane emission monitoring.” (3) These proposed revisions, which address this petition, are consistent with the EPA’s intent to “collect complete and accurate facility-level GHG emissions from the petroleum and natural gas industry” (79 FR 74484, November 30, 2010) and to provide accurate and transparent data to inform future policy decisions. Today’s proposal includes the reporting of emissions currently not covered under subpart W as well as reporting of well identification numbers which would help ensure complete, accurate, and transparent reporting of GHG data under subpart W. The EPA is proposing to allow BAMM for a limited time only for sources affected by these proposed changes; the use of BAMM for sources not addressed by the proposed changes in this action was addressed on November 25, 2014 (79 FR 70352). Finally, the EPA is currently assessing the potential opportunities for applying innovations in measurement technology to identifying and estimating emissions from affected sources under subpart W. While not explicitly adding new, alternative monitoring methods in this proposal, the EPA is seeking comment on options for allowing use of alternative monitoring methods under the GHGRP to account for advances in technology. See also, “Discussion Paper on Potential Implementation of Alternative Monitoring under the GHGRP” in Docket ID No. EPA-HQ-OAR-2014-0831.

The deadline for comments on this proposed rule is 9 February 2015,

Submit your comments, identified by Docket ID No. EPA-HQ-OAR-2014-0831 by any of the following methods:

• Federal eRulemaking Portal: http://www.regulations.gov. Follow the online instructions for submitting comments.
• Email: A-and-R-Docket@epa.gov. Include Docket ID No. EPA-HQ-OAR-2014-0831 or RIN No. 2060-AS37 in the subject line of the message.
• Fax: (202) 566-9744.
• Mail: Environmental Protection Agency, EPA Docket Center (EPA/DC), Mailcode 28221T, Attention Docket ID No. EPA-HQ-OAR-2014-0831, 1200 Pennsylvania Avenue NW., Washington, DC 20460. In addition, please mail a copy of your comments on the information collection provisions to the Office of Information and Regulatory Affairs, Office of Management and Budget (OMB), Attn: Desk Officer for EPA, 725 17th Street, NW., Washington, DC 20503.
• Hand/Courier Delivery: EPA Docket Center, Room 3334, EPA WJC West Building, 1301 Constitution Avenue NW., Washington, DC 20004. Such deliveries are accepted only during the normal hours of operation of the Docket Center, and special arrangements should be made for deliveries of boxed information.

Additional Information on Submitting Comments: To expedite review of your comments by agency staff, you are encouraged to send a separate copy of your comments, in addition to the copy you submit to the official docket, to Carole Cook, U.S. EPA, Office of Atmospheric Programs, Climate Change Division, Mail Code 6207A, 1200 Pennsylvania Avenue NW., Washington, DC 20460, telephone (202) 343-9263, email address: GHGReportingRule@epa.gov.

There are not many comments yet in Docket ID No. EPA-HQ-OAR-2014-0831: all of four total; all by fossil fuel industry organizations. Ironically, I agree with the latest one, by the Gas Processors Association, on 13 January 2015, which is “a request for an extension of time to file comments”.

Even without an extension, there’s still time to file comments.

-jsq

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