Differentiated Gas Coordinating Council Responds to the Environmental Protection Agency’s Proposed Greenhouse Gas Subpart W Reporting Rule
Differentiated Gas Coordinating Council
For Immediate Release
October 4, 2023
Contact: info@dgccouncil.com
NEWS: Differentiated Gas Coordinating Council Encourages the Environmental Protection Agency to Align with Congressional Intent, Promote the Expansion of the Differentiated Gas Market, and Coordinate with States Leading in Emissions Reporting
WASHINGTON – The Differentiated Gas Coordinating Council (DGCC), a coalition of stakeholders across the natural gas supply chain dedicated to expanding the market for low-methane-loss, “differentiated” natural gas, submitted comments in response to the Environmental Protection Agency’s (EPA) proposed rule, “Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems,” which would shift the nation’s Greenhouse Gas Reporting Program (GHGRP) away from estimated emissions toward empirical data.
"The natural gas sector's swift digital evolution and rapid adoption of innovative emissions technologies are at risk of being stalled by EPA's current proposal," said DGCC Executive Director Tom Hassenboehler. "A dynamic, innovation-driven approach is vital."
In its comments, the DGCC proposed several recommendations:
Align with Congressional Intent: The DGCC calls on EPA to match its proposed rule with Congress's directives under the Clean Air Act's Section 136(h). This section requires EPA to allow operators to use empirical methods to show that a facility's actual emissions are lower than standard Subpart W estimates, ensuring that pathways exist for advanced technologies to be utilized for reporting.
Promote the Expansion of the Differentiated Gas Market: The DGCC urges EPA to foster the growth of the differentiated gas market for affordable and verifiable emissions reduction. Specifically, the DGCC requests EPA to:
Allow the use of advanced measurement tools in the GHGRP;
Adopt a flexible technology-approval framework similar to the Methane Supplemental Rule; and
Re-evaluate its treatment of continuous monitoring technologies in the proposed rule.
Collaborate with State-Level Reporting: The DGCC urges EPA to harmonize its proposed rule to ensure states can continue leading in new, innovative emissions reporting approaches. Aligning with such state-led initiatives promotes market transparency, improved data quality, and accelerated and sustained greenhouse gas emission reductions.
In a rapidly changing energy landscape, the DGCC remains steadfast in its commitment to advancing the differentiated gas market. The DGCC's recommendations aim to reduce barriers to adopting innovative technologies that can unlock better options for operators, consumers, and regulators to rapidly detect, quantify, and mitigate emissions events. The DGCC looks forward to working closely with EPA and other stakeholders in achieving shared objectives for a cleaner environment and a more robust energy market.
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Established in 2022, the DGCC is an ad hoc coalition of stakeholders across the natural gas supply chain dedicated to expanding the market for low methane, “differentiated” natural gas. Its members include academics; downstream, midstream, and upstream energy producers; gas customers; and technology companies. The DGCC’s goal is to facilitate a federal pathway for state regulators, utilities, and gas consumers to accept differentiated gas as an important option to meet their climate goals. We believe that the adoption of differentiated gas is the best way to rapidly reduce methane emissions in the oil and gas sector—a win for American energy producers, energy consumers, and the climate.