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OIPA files comments on GHG reporting rule

June 01, 2010
TOPICS: Air
The OIPA submitted comments to the U.S. Environmental Protection Agency (EPA) on its proposed rule requiring the reporting of greenhouse gas (GHG) emissions from onshore petroleum and natural gas production, including enhance recovery (ER) projects using carbon dioxide (CO2).

EPA’s proposal requires operators of onshore production facilities to report total vented, fugitive, and combustion GHG emissions from all facilities within a basin that are 25,000 metric tons or more of CO2 equivalent per year.

OIPA commented on EPA’s proposal to change the definition of “facility” that would require companies to aggregate emissions from all sites within a basin triggering the reporting threshold.  OIPA commented that the proposed aggregation of crude oil and natural gas production sites is contrary to the Clean Air Act definition of a “facility” and to subsequent interpretations that industry and regulators understand.  Additionally, EPA is targeting the oil and gas industry and not applying the new definition of “facility” to other industry sectors.    

OIPA also commented on the impacts of the proposed rule on small crude oil and natural gas businesses, especially those that operate marginal wells.  EPA has stated many times it wants to limit the impacts to small businesses.

However, EPA’s proposed rule requiring aggregation of oil and gas sites would subject many small businesses to the proposed requirements.  In addition, OIPA commented on the need for EPA to develop easy to understand screening tools to help oil and gas operators determine applicability without the need to hire consultants.  

EPA’s proposed requirements include operators reporting emissions from drilling and completion operations even though the equipment and activity is controlled by service companies.  OIPA commented that such an approach is unreasonable and inappropriate and should be removed from the proposed rule.

The proposed rule would require operators to begin collecting emission data on January 1, 2011. Reports would be submitted annually with the first report due to EPA by March 31, 2012.  OIPA commented that operators need more time based on the sheer number of wells and the lack of available, qualified consultants that are needed to help operators comply.   

In addition, OIPA commented that the collection of annual emissions from marginal wells is overly burdensome since the production from these wells does not change substantially from year to year.  OIPA recommended EPA require reporting from small oil and gas businesses operating marginal wells no sooner than once every 5 years.

Finally, many of the comments OIPA submitted on the oil and gas production activities were applicable to the requirements EPA proposed for facilities using CO2 in ER projects.  In addition, OIPA commented that these types of facilities should have a reporting threshold, not an “all-in” requirement just because of the activity; that the collection of concentration and mass flow/volumetric flow data, and record keeping on a quarterly basis is unreasonable and should be less frequent if there are no significant changes in the CO2 source or process; and facilities should be able to cease reporting below a certain threshold or when wells are plugged.  

EPA plans to use the data it obtains to gain a better understanding of where GHGs are coming from and to develop policies and programs to reduce emissions.
For more information, go to www.epa.gov/climatechange/emissions/proposedrule.html.  

 
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