INGAA and its members have worked with EPA on greenhouse gas (GHG) projects dating back to the Gas Research Institute (GRI) project with EPA in the early 1990s that estimated methane emissions from natural gas systems. The GRI-EPA Reports2 remain a seminal reference for GHG estimates for natural gas operations two decades after its completion. Over the past five years, INGAA has worked with EPA on the Greenhouse Gas Reporting Program (GHGRP)3 and the Subpart W rulemakings in an effort to improve natural gas transmission and storage (T&S) national inventories and emission estimates. INGAA and its members have demonstrated their commitment and cooperation in improving GHG emission inventories and reducing methane emissions.
- The Proposed Framework does not rely on established and proven methods from the EPA STAR program.
- EPA’s Proposed Framework is ineffective since it applies the same approaches across all sectors.
- The STAR Gold Program should recognize that the vast majority of methane emissions come from a small number of sources.