February 11, 2011

The Honorable Lisa P. Jackson, Administrator

U.S. Environmental Protection Agency

Ariel Rios Building 

1200 Pennsylvania Avenue, NW

Mail Code: 1101A 

Washington, D.C. 20460 

Re: Request for Administrative Reconsideration Subpart W of the Mandatory Reporting of 

Greenhouse Gases Rule: Petroleum and Natural Gas Systems

Dear Administrator Jackson:

The Gas Processors Association (“GPA”) hereby requests that the U.S. Environmental 

Protection Agency (“EPA” or the “Agency”) reconsider Subpart W of the Mandatory Reporting 

of Greenhouse Gases: Petroleum and Natural Gas Systems; Final Rule, published at 75 Fed. Reg. 

74458 (Nov. 30, 2010) (“Subpart W”). Pursuant to § 307(d)(7)(B) of the Clean Air Act 

(“CAA”), 42 U.S.C. § 7607(d)(7)(B), where it is impracticable to raise an objection during the 

period of public comment or if the grounds for such an objection arise after the public comment 

period (but within the time specified for judicial review), and if such objections are of central 

relevance to the outcome of the rule, EPA is authorized to reconsider a rule.

GPA is a non-profit trade organization made up of approximately 120 corporate 

members, all of whom are engaged in the processing of natural gas into merchantable pipeline 

gas, or in the manufacture, transportation, or further processing of liquid products from natural

gas. GPA’s membership accounts for approximately 92 percent of all natural gas liquids 

produced by the midstream energy sector in the United States. Our members also produce, 

gather, transmit, and market natural gas and natural gas liquids, and include a number of 

Canadian and international companies that produce natural gas liquids on a global scale.

As described more fully below, GPA is requesting reconsideration of the following key

aspects of Subpart W. GPA’s objections to these aspects of the final rule arose after the close of 

the public comment period and are of central relevance to the outcome of the final rule. Thus, 

reconsideration is authorized and appropriate. GPA’s objections are as follows:

1. Subpart W’s best available monitoring method (“BAMM”) provisions do not provide

reporting entities with adequate time to ensure compliance with the final rule.

2. Current compressor venting monitoring requirements are overly burdensome and present 

significant safety and operational process concerns to reporting entities.
The Honorable Lisa P. Jackson, Administrator

February 11, 2011

Page 2

3. The terms “gathering lines” and “booster stations” are not defined in the final rule, nor is 

sufficient detail provided regarding the definition of “gas processing facility.” Absent 

such definitions and clarifications, there will be substantial confusion as to which 

facilities are required to report emissions data.

4. The definition of a facility in Subpart W differs from the definition of a facility provided 

in all other applicable regulations under the Clean Air Act (“CAA”). This inconsistency 

will create unnecessary confusion among related programs and is not necessary or 

justified.

These objections are discussed in detail below.

1. Subpart W’s best available monitoring method (“BAMM”) provisions do not 

provide reporting entities with adequate time to ensure compliance with the final 

rule.

GPA member companies are currently assessing the availability of each individual data 

source required by the Subpart W to perform required calculations and comply with the rule. 

This process is arduous and time-consuming and requires significant personnel from many facets 

of GPA’s member companies’ complex organizations. The time period EPA has provided 

reporting entities to analyze their existing systems, identify parameters for which BAMM is 

required, and prepare and submit BAMM or BAMM extension requests is impractical and 

unrealistic.

Existing BAMM provisions are difficult to comply with, as BAMM is provided only for 

specific sources and methodologies. Given the significant complexities of the rule and the 

plethora of data parameters that must be assessed and collected for compliance, the use of 

BAMM provisions for one data point of an equation but not for others does not provide 

significant relief for reporting entities. Furthermore, because some of the data required under 

Subpart W may be BAMM estimates, but others must be actual data points, the final rule will 

result in inconsistencies that may impede reporting entities’ efforts to comply with the rule.

Additionally, the information required to be submitted in BAMM extension requests puts 

a considerable burden on reporting entities, especially where their time and resources would be 

better spent preparing and collecting data for compliance with Subpart W. For those data points 

identified for which BAMM is necessary, reporting entities are highly unlikely to be able to 

discuss, contract with, and collect the documentation required to support the BAMM request 

within the given timeframe.

EPA does not provide any deadlines in the final rule within which they will respond to 

BAMM extension requests, which is of considerable concern to reporting entities that will rely 

on BAMM to comply with Subpart W in the first year of reporting. Reporting entities will face 

significant uncertainty while waiting to hear from EPA on whether the request has been 

approved and may be left in an untenable position if EPA denies BAMM requests.
The Honorable Lisa P. Jackson, Administrator

February 11, 2011

Page 3

As a result, GPA requests that BAMM should be provided, without request, for entities 

impacted by Subpart W for the entire first reporting year (2011) and for all data points required 

for calculation methods prescribed by the rule.

2. Current compressor venting monitoring requirements are overly burdensome and 

present significant safety and operational process concerns to reporting entities.

The direct monitoring and measurement requirements under Subpart W for compressors 

are unnecessary and unwarranted for an emissions inventory and reporting rule. Widely

accepted estimation methods are available to calculate emissions from compressors that can 

deliver accurate results without requiring direct measurements. Furthermore, such direct 

measurement requirements are duplicative of ongoing EPA research and therefore not necessary 

under the reporting rule. In the rule’s Technical Support Document, EPA states that the data 

from the direct measurement portions of the rule is necessary to support future climate-related 

regulatory efforts, though no information is provided as to what such efforts are or what they will

involve. Given the substantial burden Subpart W’s direct measurement requirements place on 

reporting entities, EPA is not justified in seeking to impose such costs on industry absent a 

detailed showing as to the Agency’s needs and plans for such information.

Additionally, the final rule requires reporting entities to calculate emissions from 

centrifugal compressors for both wet seal and dry seal venting and from blowdown valve vents. 

These requirements, which were absent from the proposed rule, will more than double the 

number of measurements originally anticipated for centrifugal compressors and result in a 

substantial additional and unanticipated burden to measure, collect, and quantify such data. 

The final rule also requires reporting entities to calculate emissions from reciprocating 

compressor blowdown valve vents. The proposed rule had only required emissions calculations 

for rod pack venting and unit isolation valve venting systems. This new and, again, 

unanticipated set of requirements will more than double the number of measurements for 

reciprocating compressors. 

Finally, Subpart W requires annual measurements on each vent for each compressor, and 

the final rule indicates under § 98.233(o)(1) and § 98.233(p) that if sources are vented through a 

common manifold, each vent source must be measured separately. In practical terms, it is not 

possible for reporting entities to comply with this requirement under current operating 

conditions. Compliance would require pipes to be cut in order to provide adequate access points 

to install meter ports. This would result in entire facilities needing to be shut down, blown down, 

and purged in order to ensure appropriate safety conditions to proceed with such pipe 

modifications — again representing an excessive, overly burdensome, and avoidable compliance 

burden for reporting entities.

GPA therefore requests that EPA allow for the use of accepted estimation methods 

available to calculate emissions from compressor vents in lieu of conducting direct 

measurements.
The Honorable Lisa P. Jackson, Administrator

February 11, 2011

Page 4

3. The terms “gathering lines” and “booster stations” are not defined in the final rule, 

nor is sufficient detail provided regarding the definition of “gas processing facility.”

Subpart W states under § 98.230(a)(3) that gathering lines and booster stations are 

excluded from reporting obligations. However, the definition of a gas processing facility also 

includes several processes typical of standard booster stations (i.e., water removal). This 

definition therefore seems to imply that booster stations exhibiting any of these characteristics 

with an average annual throughput ≥ 25 MMscfd are subject to Subpart W’s reporting 

requirements. Definitions of gathering lines and booster stations appeared in the proposed rule, 

but were removed from the final rule. Without such definitions, GPA and its member companies 

are concerned that their reporting liability could inappropriately extend to booster stations falling 

under the definition provided under § 98.230(a)(3).

In addition, Subpart W’s definition of source category under § 98.230 lists several types 

of operations, including onshore natural gas processing and onshore petroleum and natural gas 

production, but fails to specify how a reporting entity can determine under which type of 

operation certain types of activities or facilities that can occur in more than one type of operation 

should fall. For example, a facility that removes water could fall under either onshore natural 

gas processing or onshore petroleum and natural gas production. Accordingly, the source 

category definition is a source of considerable confusion and uncertainty for reporting entities. 

GPA requests that EPA reinstate the definitions of gathering lines and booster stations 

from the proposed rule and clarify and align each source category to definitions already provided 

in the CAA (e.g., Natural Gas Processing Facility under NSPS KKK).

4. The current definition of a facility in Subpart W differs from the definition of a 

facility provided in all other applicable regulations under the Clean Air Act 

(“CAA”).

The final rule requires production operations to be aggregated on basin-wide basis for 

purposes of determining the applicability of Subpart W and in meeting subsequent reporting 

obligations. This approach is fundamentally inconsistent with the manner in which the terms 

“stationary source” or “facility” are defined for all other purposes under the CAA. As a result, 

the inconsistent approach adopted in the final Subpart W rule will lead to unnecessary confusion 

and will produce data that are not useful for other CAA purposes. A particular problem is that 

the Subpart W approach will often be incompatible with actual ownership and control of the 

affected operations.

GPA requests that EPA conform the Subpart W definition of “Facility” with other similar 

definitions in other CAA regulatory programs. To avoid creating additional reporting burden, 

EPA should allow companies to “roll up” the GHG emissions from multiple affiliated stationary 

sources when reporting under Subpart W.

* * * * * * *
The Honorable Lisa P. Jackson, Administrator

February 11, 2011

Page 5

Thank you for your consideration of these concerns. If you have any questions, do not 

hesitate to contact me at 918-493-3872.

Sincerely,

Jeff Applekamp

Director, Government Affairs

Gas Processors Association

cc: D. Kruger

P. Gunning

R. Fernandez