INGAA and its member companies have a long history of working collaboratively with a variety of stakeholders on greenhouse gas issues, including methane issues.
INGAA appreciates the opportunity to comment on EPA’s Natural Gas STAR Methane Challenge, a voluntary program designed to “reduce emissions and realize significant voluntary reductions in a quick, flexible, cost-effective way.”
INGAA supports EPA’s decision to propose a voluntary methane emission reduction program, rather than a prescriptive regulatory program, with the stated goal of achieving significant emission reductions in a cost-effective manner. INGAA also supports EPA’s decision to offer three emissions reduction options, rather than prescribing uniform program criteria. Providing multiple options will enable each company to select the emissions reduction approach that best suits its business units.
– Program should be truly voluntary.
– Flexibility is critical.
– Program should focus on the largest sources of methane.
– Reducing Methane emissions from blowdowns events is unrealistic.
INGAA urges EPA to accept the DI&M approach advocated by INGAA as a BMP for leak monitoring and repair.
INGAA’s DI&M has the potential to address over 80 percent of leak emissions from natural gas transmission and storage compressor stations.
DI&M also can help to identify “super emitters” that offer the best opportunity for cost-effective methane emissions reductions.
Modification of the Methane Challenge to incorporate DI&M as a Best Management Practice would encourage gas pipeline participation.
Please click on the PDF above to read INGAA’s comments to EPA in their entirety.