The Interstate Natural Gas Association of America (INGAA) appreciates the opportunity to comment on the Source Determination for Certain Emission Units in the Oil and Natural Gas Sector Proposed Rule.
INGAA and its member companies have a long history of working collaboratively with a variety of stakeholders on various Environmental Protection Agency (EPA or the Agency) initiatives to define the term “adjacent” more clearly for the purposes of defining the term “stationary source” under various Clean Air Act (CAA) programs.
Natural gas provides 25 percent of the basic energy needs in the United States. The 25 INGAA member companies operate approximately 200,000 miles of underground interstate pipelines and related structures that safely and reliably deliver natural gas.
INGAA member companies primarily operate in the transmission and storage segment of the natural gas sector. Activities in the transmission and storage segment should not be subject to the Proposed Rule because, by its terms, the Proposed Rule only applies to activities in oil and natural gas production segment and the natural gas processing segment.
However, out of an abundance of caution, INGAA submits these comments to: (1) urge EPA to affirm the exclusion of the transmission and storage segment from the scope of this rulemaking; and (2) encourage EPA strongly, in any event, to reject any application of Option No. 2 to the transmission and storage segment because this option would be inconsistent with statute and unworkable as applied to the transmission and storage segment.