Technical Revisions for Subparts I and W of the Greenhouse Gas Reporting Rule

The Interstate Natural Gas Association of America (INGAA), a trade association of the interstate natural gas pipeline industry, respectfully submits these comments regarding EPA's Proposed Rule, Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems. The comment package consists of 6 files. In summary, the Proposed Rule continues to require significant measurement and reporting burden for the T&S segments as reflected in several key INGAA concerns: (1) The Proposed Rule is unlikely to achieve the objective of an improved GHG inventory that supports reporting and policy objectives. Since the original 2009 proposal, INGAA has proposed alternatives that we believe would better address data gaps and ensure quality data. (2) The Proposed Rule arbitrarily retains, without adequate justification, ongoing measurement and monitoring for natural gas industry segments that is more rigorous than other industries subject to the GHGRP. Alternative methodologies are available that can better achieve program objectives, especially for key sources such as compressor related emissions. (3) INGAA strongly believes that access to alternative methodologies is imperative through Missing Data or Best Available Monitoring Method (BAMM) provisions. The Proposed Rule eliminates BAMM provisions, which may compromise the ability of affected sources to comply, especially where annual measurement may be impossible or impractical due to safety or operational concerns. INGAA recommends revisions so that the Missing Data provisions address, in its entirety, the significant void caused by eliminating BAMM. If you have any questions, please feel free to contact Lisa Beal.

Attached please find the Interstate Natural Gas Association of America's comments regarding the Mandatory Reporting of Greenhouse Gases, Technical Revisions to the Electronics Manufacturing and the Petroleum and Natural Gas Systems Categors of the Greenhouse Gas Reporting Rule, Docket Number EPA-HQ-OAR-2011-0512. If you have any questions please do not hesitate to contact us.