INGAA supports a mandatory federal climate change program that would preempt redundant and potentially conflicting state or regional initiatives. As Congress considers legislation mandating greenhouse gas reductions, INGAA urges lawmakers to ensure that climate change legislation:
- Minimizes the burden on the economy and does not cause undue harm to the natural gas pipeline industry and its customers.
- Recognizes that the use of natural gas should be part of any climate change policy and does not discriminate against natural gas relative to other fossil fuels;
- Relies on market-based approaches that are simple to administer and provides clear price signals that permit industry to select the most efficient and cost-effective solutions;
- Recognizes that, if any carbon policy regime is developed, the point of regulation, and consequent responsibility for possession and surrender of any allowances should not be placed upon service providers such as transporting pipelines;
- Ensures that early efforts to reduce greenhouse gases (GHG) emissions are recognized and rewarded;
- Supports research and development and appropriate funding for technology development to reduce greenhouse gas emissions, including those from our facilities;
The natural gas pipeline industry faces enormous opportunities and challenges as the United States considers enacting and implementing a national program for reducing GHGs. INGAA recognizes the importance of an effective national policy for addressing climate change and is actively engaged with policymakers to understand the comparative economic and operational effects that would result from alternative regulatory approaches.
Importance of Natural Gas
While natural gas has received little attention in the Congressional debate around global climate change thus far, this fuel undoubtedly will play a critical role in reducing U.S. and global GHG emissions. Natural gas is the cleanest burning of all fossil fuels and emits half the carbon dioxide per unit of energy as coal when burned. INGAA believes that natural gas will be a “bridge” between our current carbon-intensive economy and a low- carbon future. We agree that significant new low emissions energy resources such as nuclear and renewable generation, as well as coal generation with carbon sequestration, and energy efficiency advances will be part of the worldwide solution for GHG reductions. Yet some of these technologies remain several decades away from large-scale commercial deployment. Natural gas provides affordable and reliable energy today and can be counted on to contribute to both near-term and mid-term GHG emission reductions. Still, natural gas can be a part of the climate change solution only if the United States has the supplies and infrastructure it needs to meet growing natural gas demand.
Key Regulations Impacting The Natural Gas Transmission Industry
EPA Greenhouse Gas Tailoring Rule
EPA is developing a rule to limit the applicability of greenhouse gas emission regulations under the Clean Air Act’s (CAA) Prevention of Significant Deterioration and Title V operating permit programs to sources that emit at least 25,000 tons per year of CO2e of CO2, CH4, N2O, HFCs, PFCs, and SF6, and to sources that, due to proposed modifications, would emit an additional 10,000 – 25,000 tons of CO2e per year of these gases. EPA said this “tailored” approach to the thresholds was necessary to capture only the largest GHG sources and exempt millions of small sources that Congress never intended to be regulated under the CAA’s permitting provisions.
INGAA believes, based on data from its members, that EPA has grossly underestimated the number of natural gas pipelines that would remain exposed to PSD and Title V permitting even under the thresholds proposed in the Tailoring Rule. INGAA’s comments to the rule advocate for U.S. climate change policy to be established through federal legislation, not by trying to regulate GHGs under the CAA or any other existing statute. Without retreating from that belief, INGAA offers concrete suggestions for modifying the rule. EPA proposed the rule in late 2009 and is expected to issue a final rule by April, 2010.
EPA Greenhouse Gas Reporting Rule
In September, 2009 EPA issued a final rule requiring the reporting from large industrial sources with emissions greater than 25,000 metric tons per year of CO2e. These sources are required to report their GHG emissions beginning in 2011. Additionally, EPA is proposing another set of reporting rules that will address oil and natural gas industry fugitive methane emissions.
INGAA shares EPA’s desire to collect accurate, reliable and reasonably complete data on greenhouse gas emissions and the desire to improve the quality of data, especially on fugitive emissions of methane at compressor stations along natural gas pipelines. For fugitive emissions, INGAA’s comments suggest an approach that combines state-of-the-art operations information with recognized statistical sampling techniques to produce superior data.