Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems

The Environmental Commenters (EDF, CATF, NRDC, Sierra Club, and Earthworks) argue that current source-level reporting systematically underreports methane emissions. They recommend integrating top-down empirical data (satellite, aerial, and tower measurements) to validate bottom-up inventories. Key technical recommendations include establishing a 100 kg/hr threshold for 'large release events,' requiring continuous metering for a sample of pneumatic controllers to prevent data manipulation, and updating gathering pipeline emission factors using recent aerial studies rather than outdated distribution pipeline data. The group also emphasizes the need for rigorous reporting during ownership transfers to prevent 'transferred emissions' from escaping oversight and calls for extended reporting requirements for offshore facilities and plugged wells.

• Source-level data in the oil and gas supply chain has been found to systematically underreport total emissions, necessitating the use of top-down empirical data at regional and site levels to ensure completeness.
• The commenters support a 100 kg/hr emission rate threshold for 'other large release events,' noting that such events contribute disproportionately to total emissions and are often missed by other reporting requirements.
• To prevent operators from manipulating data under Calculation Methods 2 and 3 for pneumatic devices, the EPA should require continuous supply gas metering (Method 1) for a representative sample of controllers.
• Current gathering pipeline emission factors are based on outdated 1996 data from distribution pipelines, which are not representative of gathering lines; the commenters suggest using recent aerial data from the Permian Basin as a national proxy.
• Ownership transfers in the oil and gas sector may be used strategically to avoid emissions reporting or the methane waste charge, particularly when assets move from public to private markets or to companies with fewer environmental commitments.
• Offshore facilities exhibit significantly higher methane loss rates (23% to 66%) compared to onshore facilities in the Permian basin (3.3% to 3.7%), yet their emissions are frequently underestimated in inventories.

APA

Clean Air Task Force (2023). Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems. https://cdn.catf.us/wp-content/uploads/2023/10/03111028/subpart-w-comments.pdf

Chicago

Clean Air Task Force. Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems. 2023. https://cdn.catf.us/wp-content/uploads/2023/10/03111028/subpart-w-comments.pdf.

Wikipedia

{{cite press release |author=Clean Air Task Force |title=Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems |date=2 October 2023 |url=https://cdn.catf.us/wp-content/uploads/2023/10/03111028/subpart-w-comments.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cleanairtaskforce2023greenhouse, author = {{Clean Air Task Force}}, title = {{Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems}}, publisher = {Clean Air Task Force}, year = {2023}, month = oct, url = {https://cdn.catf.us/wp-content/uploads/2023/10/03111028/subpart-w-comments.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }