EPA’s Methane Reporting Proposal Highlights Critical Importance of Empirical and Accurate Data

(WASHINGTON) The Environmental Protection Agency today announced proposed updates to methane reporting requirements from oil and gas facilities under the U.S. Greenhouse Gas Reporting Program.

With the Inflation Reduction Act, Congress directed EPA to update the reporting program to include empirically collected data and to ensure the accuracy of total reported emissions. This is important to correct the well-documented problem of under-reporting and assess the waste charge established by the IRA’s Methane Emission Reduction Program based on actual amounts of pollution created by the industry.

“By directing EPA to update and strengthen methane emissions reporting, Congress recognized the vital importance of scientifically valid data to establish the true volume of pollution created by the oil and gas industry. We have not yet reviewed EPA’s proposal but look forward to carefully doing so and engaging with the agency and stakeholders to ensure final reporting protocols are scientifically rigorous, lead to accurate estimates of total emissions and leverage the best available measurement data”.

“To be effective, it is critically important that the program be based on the oil and gas industry’s real-world pollution impacts. Achieving an accurate picture of those emissions will require the use of top-down basin-level data alongside population-based data at smaller scales, statistical analysis that accounts for oft-overlooked intermittent emission events and guardrails to make sure company-reported data reflects what’s happening on the ground.”

• Dr. Daniel Zavala-Araiza, Senior Scientist, Environmental Defense Fund

Additional Background:

The US Congress passed the Inflation Reduction Act of 2022, which takes bold action to address the climate crisis. Multiple independent analyses show the law could reduce U.S. greenhouse gas emissions 40% below 2005 levels by 2030, providing important support for President Biden’s goal of cutting emissions in half by 2030.

The IRA also created the Methane Emissions Reduction Program, which cuts methane from oil and gas operations through a charge on wasteful emissions and funding to help reduce pollution. MERP complements forthcoming EPA regulations requiring operators to cut methane pollution from the oil and gas sector.

Importantly, MERP includes language directing EPA to update Subpart W of the U.S. Greenhouse Gas Reporting Program to include empirically collected data and to ensure the accuracy of total reported emissions from oil and gas facilities.

EPA’s current method of quantifying methane emissions is based on emissions factors that don’t fully capture emissions based on today’s oil and gas industry production, practices and equipment. Numerous studies observe methane emissions are significantly higher than current EPA estimates. A comprehensive study released in 2018 found emissions to be 60% higher than EPA figures.

It is of vital importance that EPA update its reporting program in a scientifically grounded way to address the well-known problem of underreported emissions and to ensure that the MERP waste charge is assessed on the true volume of pollution created by the oil and gas industry.

Accomplishing this will require:

• Integrating top-down, basin-level data alongside site- and equipment-level measurement data. Top-down, basin-level data provides a full picture of total emissions in a region, while site-level, population-based measurement data can provide insights of emissions at a finer resolution, all of which strengthen the accuracy of reported emissions.
• Building in appropriate statistical analysis of measurement data to provide a representative assessment of pollution at the facility and basin levels. Measurement data requires statistical analysis to account for intermittent emission events that may be missed by individual, one-time measurements.
• Defining guardrails and requiring independent verification for self-reported measurements from companies to ensure any company reported data accurate represents operations and is not limited to unrepresentative sites or equipment known to have lower emissions.