Oct 2, 2023 Industry Groups Comments to Proposed Subpart W Rule
Re: Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems; Docket No. EPA-HQ-OAR-2023-0234
The American Petroleum Institute, the American Exploration & Production Council, Independent Petroleum Association of America, The Petroleum Alliance of Oklahoma, and the American Fuel and Petrochemical Manufacturers (collectively “Industry Trades”) appreciate the opportunity to offer comments to the U.S. Environmental Protection Agency (EPA) on the proposed “Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems” (proposed on August 1, 2023). For perspectives of offshore operators, the Industry Trades encourage EPA to also review the Offshore Operators Committee (OOC) letter and incorporate them by reference herein. With this submittal, the Industry Trades seek to continue our participation in the rulemaking process as a collaborative stakeholder by providing meaningful solutions to simultaneously 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.
The oil and natural gas industry has participated as key collaborative stakeholders, advancing the EPA Greenhouse Gas Reporting Program (GHGRP) since its inception by contributing expertise and proposing alternatives that reflect the reality of the industry and its evolving day-to-day operating practices. The Industry Trades have focused on providing information that will help inform decision makers and the public about various challenges to data collection and reporting required by the rule, which includes safety, accuracy, and feasibility concerns, as well as the need to protect sensitive information and to ensure that reporting requirements are placed on the correct reporters.
These comments on EPA’s proposed revisions to Subpart W 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.