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Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review

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Edison Electric Institute filed 1 comment on this docket between Feb 2, 2022 and Feb 2, 2022. 188 other organizations filed here. The comment window closed 693d ago.

What Edison Electric Institute filed (1)

Feb 2, 2022· Comment submitted by Edison Electric Institute (EEI)· EPA-HQ-OAR-2021-0317-0799

The Edison Electric Institute (EEI) appreciates the opportunity to submit comments to the U.S. Environmental Protection Agency's (EPA's or Agency's) proposed rule, Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review (Proposal or Proposed Rule). 86 Fed. Reg. 63,110 (Nov. 15, 2021). The Agency proposes three separate actions: one addressing new sources; a second proposing guidelines for existing sources; and a third responding to a joint resolution of Congress in June 2021 under the Congressional Review Act (CRA) disapproving EPA's final rule, Oil and Natural Gas Sector: Emissions Standards for New, reconstructed, and Modified Sources, 85 Fed. Reg. 57,018 (Sept. 14, 2020). EEI is the association that represents all U.S. investor-owned electric companies. EEI members provide electricity for more than 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. EEI members invest more than $120 billion annually to make the energy grid smarter, cleaner, more dynamic, more flexible, and more secure in order to provide affordable and reliable electricity to customers. EEI members are currently undergoing a clean energy transformation. With the right policies and technologies, a 100-percent clean energy future can be more than a goal. It can be a reality. Across the industry, companies are investing in a broad range of affordable, carbon-free technologies and approaches with the goal of finding the most cost-effective ways to deliver clean, reliable energy. Advancing these technologies from idea to implementation requires time and investment. We support policies that provide dramatic increases in funding for the research, development, demonstration, and deployment of these technologies. Natural gas generation has played—and will continue to play—an essential role in continuing the clean energy transition by providing both 24/7 and quick start power, allowing for increased renewable integration and reliable power at affordable rates for customers. Strong and cost-effective federal regulations on upstream methane emissions are essential to ensuring the continued availability of natural gas as a 24/7 on-demand energy source. Please contact Alex Bond (202-508-5523) or Eric Holdsworth (202-508-5103) if you have any questions regarding EEI's comments.

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Abstract

On January 20, 2021, President Joe Biden issued an Executive Order titled ‘Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis,’ which directs the EPA to propose a rulemaking to reduce methane and volatile organic compound (VOC) emissions in the oil and natural gas sector by suspending, revising, or rescinding the previously issued new source performance standards (NSPS) and propose new regulations to establish standards of performance for methane and VOC emissions from the exploration and production, transmission, processing, and storage segments by September 2021. The EO also directs the EPA to propose new regulations to establish emission guidelines for methane and volatile organic compound (VOC) emissions from existing operations in the exploration and production, transmission, processing, and storage segments by September 2021. The purpose of this action is to review the existing NSPS and propose new requirements and propose new emission guidelines for existing sources in order to meet the requirements set forth in the Executive Order.

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