Jul 21, 2023 API and Coalition Comments Re: Revisions and Confidentiality Determinations for Data Elements under the Greenhouse Gas Reporting Rule; Docket No. EPA-HQ-OAR-2019-0424
Dear Ms. Bohman:
The American Petroleum Institute, the American Exploration & Production Council, Independent Petroleum Association of America, The Petroleum Alliance of Oklahoma, and the Offshore Operators Committee (collectively “Industry Trades”) appreciate the opportunity to offer comments to the U.S. Environmental Protection Agency (EPA) on the proposed “Revisions and Confidentiality Determinations for Data Elements under the Greenhouse Gas Reporting Rule” (proposed on May 22, 2023). With this submittal, the Industry Trades seek to continue our participation in the rulemaking process as a collaborative stakeholder by providing meaningful solutions to address EPA’s goals while addressing the burden of data collection (and identifying potential unintended consequences) that could result if the rulemaking is finalized as proposed.
We have participated as key collaborative stakeholders throughout the process of developing the EPA Greenhouse Gas Reporting Program (GHGRP) by contributing expertise and proposing solutions that address EPA’s policy goals while reflecting the reality of the industry and its evolving day-to-day operating practices. The Industry Trades have directed our efforts toward seeking a balance between the burden of data collection and reporting, the need to protect sensitive information and ensure that reporting requirements are placed on the correct reporters, and the need for providing the highest quality data that will help inform decision makers and the public.
These comments reflect our continued interest in the evolution of the GHGRP to provide an accurate accounting of greenhouse gas (GHG) emissions from facilities across the full value chain of the oil and natural gas industry. Our comments cover concerns and recommendations in the wide range of sectors that relate to the operations of our collective members. …