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EPA must strengthen accuracy of reported emissions from oil and natural gas

October 6, 2023 Work Area: Methane

WASHINGTON – Clean Air Task Force (CATF) joined other environmental groups in submitting comments urging the Environmental Protection Agency (EPA) to strengthen the proposed revision to the greenhouse gas reporting requirements for the oil and gas sector. The comments focus on improving requirements to ensure oil and gas operators accurately report the amount of methane pollution they release. 

“The science is clear: we need to reduce methane emissions to avert the worst effects of climate change, and we need to do so quickly,” said Lesley Feldman, Research and Analysis Manager at Clean Air Task Force. “EPA’s proposed rule will move us from educated guesses about methane pollution levels to actual measurements of individual sources, something that is imperative if we are to capitalize on the potential climate, air quality, and public health benefits of methane pollution reduction. But we need further improvements in the rule to provide public confidence that the data is trustworthy and empirically sound, and not distorted by manipulation of the measurements. This will also be critical for EPA to accurately assess the amount each oil and gas company owes under the new Waste Emissions Charge. We urge EPA to finalize a strong rule to ensure the reporting methods and procedures will capture the most accurate data to help bend the climate curve.” 

Congress included a directive to update subpart W of the greenhouse gas reporting program (GHGRP) in the Methane Emissions Reduction Program (MERP), included in the recently passed Inflation Reduction Act. The EPA must revise the GHGRP to accurately reflect total emissions based on empirical data, and to improve upon the existing requirements that have consistently been shown to underestimate true emissions. The revision and an accurate representation of an operator’s methane emissions is also critical to the efficacy of the Waste Emissions Charge that is part of the MERP. EPA is expected to propose rules to implement the Waste Emissions Charge later this year.  

While EPA’s proposal takes important steps to fulfill that mandate, CATF and our partners recommend strengthening the rule by: 

  • Moving towards requiring operators to accurately, continuously monitor or measure particularly problematic sources, which are known to frequently break and emit more than designed. These sources include pneumatic controllers (the largest reported source of methane from the oil and gas sector under subpart W) and hatches on tanks, which frequently fail to be properly sealed or closed, leading to large plumes of emissions; 
  • Improving EPA’s newly proposed large release events reporting category to better capture emissions from these types of events, also known as “super-emitters;” 
  • Improving the accuracy of reporting on equipment leaks by improving leak survey protocols; and 
  • Improving estimates for unburned methane from flares by requiring operators who claim that their flares operate effectively to rigorously demonstrate this. 

Read CATF’s roadmap for implementing the Methane Emissions Reduction Program here. 

Press Contact

Samantha Sadowski, Communications Manager, U.S.,, +1 202-440-1717

About Clean Air Task Force 

Clean Air Task Force (CATF) is a global nonprofit organization working to safeguard against the worst impacts of climate change by catalyzing the rapid development and deployment of low-carbon energy and other climate-protecting technologies. With 25 years of internationally recognized expertise on climate policy and a fierce commitment to exploring all potential solutions, CATF is a pragmatic, non-ideological advocacy group with the bold ideas needed to address climate change. CATF has offices in Boston, Washington D.C., and Brussels, with staff working virtually around the world. Visit and follow @cleanaircatf.

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