Feedback on the Proposal for a Legislative Act to Reduce Methane Emissions in the Oil, Gas and Coal Sectors

The document argues for a stronger legal basis under Article 192 TFEU and proposes rigorous standards for measurement, reporting, and verification (MRV), leak detection and repair (LDAR), and a ban on routine venting and flaring (BRVF). It specifically highlights the need for granular data, the inclusion of abandoned wells and mines, and the implementation of methane intensity limits to drive innovation and align with EU climate targets.

• The authors argue that the proposed legal base of Article 194 TFEU is improper because the act's objectives and policy options do not relate to energy market functioning or security of supply, but rather to environmental protection, making Article 192 TFEU the correct legal base.
• A robust Measurement, Reporting and Verification (MRV) framework should move beyond voluntary industry programs like OGMP to include mandatory EU legislation requiring granular, asset-level data available to the public in tabular formats, and independent third-party verification.
• An effective Leak Detection and Repair (LDAR) program should cover the entire supply chain for fossil gas, oil, coal, and biogas/biomethane, utilizing frequent instrument-based surveys (preferably monthly) and strict repair timelines (within 5 days for most leaks).
• The document advocates for a comprehensive ban on routine venting and flaring (BRVF) across the supply chain, including venting by design equipment, and suggests the EU consider Norway's model of combining a venting/flaring ban with a CO2 tax.
• To drive technological innovation and ensure alignment with climate targets, the EU should introduce methane emissions limits, such as a minimum methane intensity standard of 0.2% by 2025 for the upstream oil and gas industry.
• Coal mine methane (CMM) requires a distinct approach from oil and gas due to existing safety-based MRV and the significant impact of abandoned mines; the authors specifically urge a strict ban on venting from demethanisation stations, noting that 16% of Poland's CMM emissions occur there.
• The proposal recommends specific mechanisms for abandoned and unused sites, including lowering the reporting threshold for closed coal mines from 200T/year to 50T/year and establishing government-funded programs for capping and monitoring orphaned oil and gas wells.

APA

ClientEarth (2021). Feedback on the Proposal for a Legislative Act to Reduce Methane Emissions in the Oil, Gas and Coal Sectors. https://www.clientearth.org/media/zxqnspg0/feedback-on-the-proposal-for-a-legislative-act-to-reduce-methane-emissions.pdf

Chicago

ClientEarth. Feedback on the Proposal for a Legislative Act to Reduce Methane Emissions in the Oil, Gas and Coal Sectors. 2021. https://www.clientearth.org/media/zxqnspg0/feedback-on-the-proposal-for-a-legislative-act-to-reduce-methane-emissions.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Feedback on the Proposal for a Legislative Act to Reduce Methane Emissions in the Oil, Gas and Coal Sectors |date=26 January 2021 |url=https://www.clientearth.org/media/zxqnspg0/feedback-on-the-proposal-for-a-legislative-act-to-reduce-methane-emissions.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2021feedback, author = {{ClientEarth}}, title = {{Feedback on the Proposal for a Legislative Act to Reduce Methane Emissions in the Oil, Gas and Coal Sectors}}, publisher = {ClientEarth}, year = {2021}, month = jan, url = {https://www.clientearth.org/media/zxqnspg0/feedback-on-the-proposal-for-a-legislative-act-to-reduce-methane-emissions.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }