NDPC Submits Comments on EPA’s Proposed Emissions Standards

The NDPC submitted comments on EPA’s proposed regulations to manage methane emissions for oil and gas operations that would impose additional and sometimes duplicative requirements on both new and existing operations.  Compliance with the proposed regulations will undoubtedly add production and processing costs, which will result in higher costs for consumers.  Furthermore, it is not clear these additional costs will result in any significant environmental benefit.

Among the key suggestions by the NDPC was to:

• Focus on the parts of this proposal that will have the most cost-effective impact on reducing Methane and Volatile Organic Carbon (VOC) emissions going forward and reconsider some of the unnecessarily burdensome requirements, including but not limited to, regulating insignificant sources of emissions, administrative recordkeeping, and reporting requirements that do not directly or significantly impact emission reductions.
• Acknowledge the states and regions that already have emissions regulations in place and that additional or duplicative regulations add costs and administrative burden that significantly outweigh any corresponding environmental benefit.
• Propose actual regulatory text before publishing a “proposed rule” so interested parties can provide thoughtful and meaningful comments.