There is “no defensible reason” for the Environmental Protection Agency (EPA) to subject natural gas pipelines and storage facilities to regulation of emissions of volatile organic compounds (VOC), said a major interstate gas pipeline group.
Proposed EPA rules “would have far-reaching impacts on our industry, yet, for natural gas transmission and storage companies, VOC emissions are relatively minimal,” said the Interstate Natural Gas Association of America (INGAA) in a letter to EPA Tuesday. It said it “strongly objects to these proposed regulations because they do not address VOCs but instead clearly target GHG [greenhouse gas] emissions.”
Even the EPA has acknowledged that the VOC content of pipeline-quality gas is “relatively low,” the pipeline group said. “Applying operating standards on interstate natural gas pipeline and storage operations therefore would yield, at best, a very small reduction in VOC emissions. Regulations cannot significantly reduce something [that] is not significant in the first place.”
While the impact on VOC emissions would be negligible, “the cost to comply would be very high,” INGAA said. “The threatened capital and operating costs of the proposed standards are substantial, but the threatened administrative costs — monitoring, accumulating monitored data, preparing reports, maintaining archives and facilitating internal or external audits — are even more daunting and unnecessary,” the group said.
“It seems apparent that the true thrust of the proposed regulations, at least as they apply to INGAA’s members, is to reduce emissions of greenhouse gases, notably methane…Using VOC regulations as a foil for regulating greenhouse gases is premature as a matter of policy, unfounded as a matter of law, inconsistent with prevailing regulatory policy and contrary to the country’s immediate energy and environmental interests,” INGAA said.
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