cover image: Re: AGA and APGA’s Comments on “Waste Emissions Charge for Petroleum and Natural Gas Systems,” Docket ID No. EPA-HQ-OAR-2023-0434

20.500.12592/j9kdbkd

Re: AGA and APGA’s Comments on “Waste Emissions Charge for Petroleum and Natural Gas Systems,” Docket ID No. EPA-HQ-OAR-2023-0434

26 Mar 2024

accurately reflect the total methane emissions and waste emissions from the applicable facilities, and allow owners and operators of applicable facilities to submit empirical emissions data” to demonstrate the extent to which the WEC is owed.42 EPA issued its proposed Subpart W revisions in August 2023,43 and is aiming to issue a final rule in April 2024.44 As of the date of these comments, the fi. [...] AGA and APGA WEC Comments | 8 The Associations ask EPA to specifically call out the fact that the NAICS definition of “natural gas distribution” is broader than the Subpart W definition, the Subpart W definition is the one that is relevant to WEC applicability, and Section 136(d) excludes the Subpart W-defined natural gas distribu. [...] The Associations encourage EPA to make clearer throughout the proposed regulatory text, the preamble, and other EPA guidance that natural gas distribution as defined in Subpart W is completely outside of the scope of the WEC applicability determination. [...] The Associations agree with the comments submitted by the Interstate Natural Gas Association of America (“INGAA”) regarding EPA’s proposed implementation of the exemption for regulatory compliance with the methane NSPS/EGs pursuant to Section 111 of the Clean Air Act.68 Specifically, the Associations agree with INGAA that the Section 136(f)(6) regulatory compliance exemption should be available on. [...] To implement the methane fee program, Congress required EPA to revise Subpart W within two years (by August 16, 2024) to ensure that reporting and calculation of the methane charge are based on empirical data to accurately reflect the total methane emissions and waste emissions from the applicable facilities, and to allow owners/operators to submit empirical emissions data to demonstrate the exten.

Authors

Golinsky Baseman, Jennifer

Pages
122
Published in
United States of America