DGCC Provides Recommendations to Ensure Advanced Methane Technology Approvals are Harmonized, not Handicapped, in Regulatory Actions

Differentiated Gas Coordinating Council

For Immediate Release

January 10, 2024

Contact: info@dgccouncil.com

NEWS: Differentiated Gas Coordinating Council Provides Recommendations to Ensure Advanced Methane Technology Approvals are Harmonized, not Handicapped, in Regulatory Actions

WASHINGTON - As the House Energy and Commerce Committee evaluates the Environmental Protection Agency’s (EPA) methane regulations and programs, the Differentiated Gas Coordinating Council (DGCC) previews recommendations to harmonize rulemaking processes affecting methane across the federal government.

Throughout the oil and gas sector, many companies are already using advanced technologies, including continuous emissions monitoring systems, aerial surveys, and satellites, to directly measure facility emissions and to detect and repair methane leaks. These technologies are at the heart of voluntary initiatives to improve site-level monitoring and measurement of methane emissions. They enable more frequent and more accurate measurements, which are preferred over outdated emission estimates or emissions factors currently used by EPA.

DGCC — a coalition of stakeholders across the natural gas supply chain dedicated to expanding the market for low-methane-loss, “differentiated” natural gas — recommends the Biden Administration rely on key provisions from EPA’s final New Source Performance Standards (NSPS) OOOOb/Emission Guidelines (EG) OOOOc Rule to promote efficiency and consistency across all of the Administration’s other methane rulemakings and reporting requirements. DGCC also recommends that the Administration, under its whole of government approach to the regulation of methane, create a centralized and streamlined process for approving technologies that can be used to meet various regulatory requirements. For example, in addition to EPA, the Bureau of Land Management (BLM) and the Pipeline and Hazardous Materials Safety Administration (PHMSA) have methane-related rulemakings underway. Ensuring that the same technologies that are approved under one agency’s rules can be used for another agency’s requirements will guarantee regulatory efficiency, consistency, and effectiveness.

EPA’s robust model for approving and integrating advanced methane detection methods on an ongoing basis in the NSPS OOOOb/EG OOOOc Rule should serve as a framework for continuous review and approval of advanced technologies and rigorous performance criteria. Since this rulemaking covers a large part of the natural gas supply chain, such as production, gathering and boosting, transmission, and storage segments, its approach to approving advanced methane technologies and methodologies should be coordinated across the federal government, including:

Final Subpart W Rule: EPA should establish a framework in the Final Subpart W Rule that uses EPA’s NSPS OOOOb/EG OOOOc Rule’s approval process with performance criteria tailored to the methane quantification methodology needed for the Methane Fee.

Measuring, Monitoring, Reporting, and Verification (MMRV) Framework: The Department of Energy should align its MMRV framework with EPA’s NSPS OOOOb/EG OOOOc Rule by relying on EPA-approved definitions and methodologies as standard benchmarks for monitoring and measurement.

Final Waste Prevention Rule: The BLM’s final Waste Prevention Rule should provide automatic or expedited approval in its waste minimization permit plans for the use of advanced technologies and methodologies that were approved under EPA’s NSPS OOOOb/EG OOOOc Rule.

Final Gas Pipeline Leak Detection and Repair Rule: PHMSA should rely on EPA’s NSPS OOOOb/EG OOOOc Rule’s approved technologies and methodologies for compliance with pipeline system methane detection requirements.

45V Clean Hydrogen Production Tax Credit: The Department of Treasury should look to EPA’s NSPS OOOOb/EG OOOOc Rule’s approved technologies as reliable measured data to calculate the methane emissions portion of the life cycle analysis underpinning the tax credit.

Final Climate Disclosure Rule and Federal Acquisition Regulation (FAR) Rule: The Securities and Exchange Commission and the Department of Defense’s disclosure requirements should point to EPA’s NSPS OOOOb/EG OOOOc Rule as an approved and reliable methodology for accurate methane reduction disclosures.

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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.