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Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Review

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Edison Electric Institute filed 1 comment on this docket between Dec 3, 2019 and Dec 3, 2019. 59 other organizations filed here. The comment window closed 2437d ago.

What Edison Electric Institute filed (1)

Dec 3, 2019· Comment submitted by Emily S. Fisher, General Counsel and Corporate Secretary, Edison Electric Institute (EEI) and American Gas Association (AGA)· EPA-HQ-OAR-2017-0757-1820

The Edison Electric Institute (EEI) and American Gas Association (AGA) appreciate this opportunity to submit comments on the proposed rule from the Environmental Protection Agency (EPA or Agency) regarding the Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Review (Proposed Methane Rule). 84 Fed. Reg. 50,244 (Sept. 24, 2019). EEI is the association that represents all U.S. investor-owned electric companies. Our members provide electricity for about 220 million Americans, and operate in all 50 states and the District of Columbia. As a whole, the electric power industry supports more than seven million jobs in communities across the United States. The electric power industry is in the middle of a profound, long-term transformation in how electricity is generated, transmitted, and used. This transformation is being driven by a wide range of factors, including: declining costs for natural gas and renewable energy resources, technological improvements, changing customer expectations, federal and state regulations and policies, and the increasing use of distributed energy resources. As a result, the mix of resources used to generate electricity in the United States has changed dramatically over the last decade and is increasingly clean. AGA, founded in 1918, represents more than 200 local energy companies that deliver clean natural gas throughout the United States. There are more than 74 million residential, commercial and industrial natural gas customers in the U.S., of which 95 percentmore than 71 million customersreceive their gas from AGA members. AGA is an advocate for natural gas utility companies and their customers and provides a broad range of programs and services for member natural gas pipelines, marketers, gatherers, international natural gas companies and industry associates. Today, natural gas meets more than one-fourth of the United States' energy needs. Electric companies view the continued use of natural gas generation as necessary to continuing the clean energy transition in a way that is both reliable and affordable. Additionally, electric and gas distribution companies recognize that continued methane emissions reductions attributable from the natural gas supply chain are important to demonstrate the carbon dioxide reductions attributable to coal-to-gas switching and to support company sustainability and greenhouse gas reduction goals. Accordingly, AGA and EEI created a joint CEO Natural Gas Task Force to develop and deploy the Natural Gas Sustainability Initiative (NGSI), a voluntary, industry-led effort to advance innovative and voluntary sustainability efforts throughout the natural gas supply chain from production through end-use. EEI and AGA members recognize the need to address methane emissions. NGSI, therefore, aims to provide consistency and comparability to these measurements throughout the supply chain and to encourage continuous improvement in methane emissions reductions through company-level disclosure. NGSI is viewed as an important tool to help standardize and contextualize supply chain emissions, specifically for methane. This initiative is designed to be additive and complementary to other efforts and is intended to work in concert with regulatory standards, which are a critical aspect to providing certainty to both the regulated industry and its customers in the supply chain. Ensuring that methane emissions from the entire natural gas supply chain are minimized is critical to the industry's ability to continue to utilize natural gas. EEI and AGA appreciate the opportunity to submit these comments for consideration. Please contact Alex Bond (abond@eei.org; 202-508-5523), Eric Holdsworth (eholdsworth@eei.org; 202-508-5103), or Dr. Karen Obenshain (kobenshain@eei.org; 202-508-5223) with any questions regarding EEI. Please contact Lori Traweek (ltraweek@aga.org) or Pamela Lacey (placey@aga.org) with any questions regarding AGA.

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Abstract

Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Reconsideration

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