Environmental Protection Agency (EPA) Methane White Paper 

Oil and Natural Gas Sector Pneumatic Devices 

INGAA Comments 

1. Introduction 

The Interstate Natural Gas Association of America (INGAA), a trade association of the interstate 

natural gas pipeline industry, submits these comments on the EPA’s technical white paper, “Oil 

and Natural Gas Sector Pneumatic Devices” (Pneumatics Paper). On April 15, 2014, the EPA 

released five technical white papers discussing potentially significant sources of emissions in the 

oil and natural gas sector. Specifically, the white papers focus on potential emissions and 

mitigation techniques for methane and volatile organic compounds (VOCs). INGAA is 

submitting separate comments on the three papers (Compressors, Leaks and Pneumatics) that 

address sources applicable to the interstate natural gas transmission and storage (T&S) sector. 

These comments address the Pneumatics Paper. 

In the Pneumatics Paper, EPA summarized its current understanding of VOC and methane 

emissions from this source category, and its current understanding of available mitigation 

techniques and the cost, effectiveness and application of these techniques in the oil and natural 

gas sector. EPA has requested comment on nine questions related to the contents and 

conclusions of the Pneumatics Paper. 

INGAA and its member companies have a long history of working collaboratively with a variety 

of stakeholders on numerous greenhouse gas (GHG) related issues, including methane 

quantification and mitigation. As such, INGAA welcomes the opportunity to contribute its 

knowledge of emissions and available control technologies. INGAA commends EPA for 

involving stakeholders and inviting comment on the methane white papers. 

Executive Summary 

INGAA has three general points in response to EPA’s white papers. First, there are significant 

differences in the methane emission estimates produced by EPA’s Inventory of U.S. Greenhouse 

Gas Emissions and Sinks (the National Inventory) and the Subpart W portion of its Greenhouse 

Gas Reporting Program (GHGRP).1

 There also are significant gaps in the information available. 

EPA needs to develop a systematic program to reconcile these differences and fill the gaps in 

order to support further discussion on methane reductions. Second, INGAA recommends 

additional discussion and analysis of the implications, including costs, of potential mitigation 

methods. Finally, EPA should recognize that new information will be available soon to 

supplement this discussion. 

                                                            

1 See http://www.epa.gov/ghgreporting/ and http://www.epa.gov/ghgreporting/reporters/subpart/w.html (Starting 

with the 2011 calendar year for Subpart W, the GHGRP requires pipeline companies to submit annual reports of 

GHG emissions for subject facilities. Pipelines must submit 2014 emission information for the fourth annual report 

by March 31, 2015).
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In response to the Pneumatics Paper specifically, INGAA offers the following comments: 

1. EPA should reevaluate whether pneumatics are relevant to the interstate natural gas 

transmission and storage (T&S) sector. INGAA submits that pneumatics is an upstream 

issue but not a significant emission source for the T&S sector. 

2. Gas-driven pneumatics are needed for some process applications to address rapid process 

control, possibly due to safety concerns, such as large valves that are used to isolate 

portions of the facility or pieces of equipment. 

INGAA welcomes the opportunity to contribute to this discussion.

Overview of INGAA Responses 

INGAA has attempted to answer each question to the best of its ability. Due to time and other 

limitations, however, INGAA has not answered all questions fully. For some questions, INGAA 

could not respond completely because this will require a significant long-term effort (e.g., a 

research program) that includes all stakeholders. For example, questions regarding technology 

prevalence, cost implications and technical feasibility impacts would entail an integrated 

research effort to provide a quality, validated and vetted answer. In most cases, however, 

INGAA has provided a thorough response with the information available while noting the gaps 

in existing data. Whenever possible, INGAA offers specific examples of field conditions and 

industry experience. Appendix A provides a quick reference to EPA’s questions on pneumatic 

devices and INGAA’s response. 

2. Establish an Open Process That Involves All Stakeholders to Further Examine Methane 

Reduction Issues 

Other than the Natural Gas STAR program, EPA has focused its oil and gas industry GHG 

efforts primarily on quantifying or estimating methane emissions. EPA must consider a number 

of issues, including economic, operational and environmental issues as it moves toward a 

broader methane strategy. 

INGAA envisions a process that is transparent and inclusive of industry and other stakeholders to 

examine issues and potential strategies. This has proven effective at other federal agencies and 

for other EPA regulations. For example, EPA could host technical conferences similar to those 

convened by the Federal Energy Regulatory Commission (FERC) to examine critical issues prior 

to initiating a rulemaking.2

 

                                                            

2

 FERC typically holds public technical conferences to gather information on important policy issues and to hear 

potentially competing positions in advance of issuing significant rulemakings. For example, in 2012-2013, FERC 

held a series of technical conferences to explore issues surrounding the increased use of natural gas for electric 

power generation and issues that may impede coordination between the gas and electric industries. After 

considering discussions raised by interested stakeholders at the 2012-2013 technical conferences, and subsequent 

public comments, the FERC initiated two rulemakings that propose to address concerns raised by participants at the 

technical conferences. Technical conferences provide the benefit of educating the regulator and other stakeholders 

on a particular issue and facilitating a structured dialogue where stakeholders can debate the effectiveness or need 

for prospective action prior to the issuance in a proposed rulemaking. Often technical conferences can reveal 

stakeholder support for certain initiatives, identify potential flaws in certain proposals, and identify alternative ways 

to address the regulator’s or stakeholders’ concerns. 
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This process would provide an efficient and effective means to advance the current 

understanding of methane emissions and how to design effective programs. As an example, the 

EPA GHGRP is intended to develop improved GHG inventories and to inform policy decisions.3

 

Subpart W of the GHGRP addresses T&S segment emissions from vents and equipment leaks 

and companies have submitted three years of data to date. Data is publicly available for the 2011 

and 2012 reporting years,4

 and indicate significant disparities between Subpart W reporting and 

the U.S. National Inventory5 for T&S sources. These differences are due in part to differences in 

scope but also other reasons. It is very important that these differences are understood and that a 

single, accurate inventory is in place before EPA or industry can develop and implement 

effective and efficient mitigation strategies. These proposed technical conferences or workshops 

can provide EPA and industry the platform to discuss these important issues so that EPA’s future 

methane reduction policies reflect all relevant analysis. 

3. Sources of Information on Emissions and Reduction Opportunities6 

EPA has requested comment on whether the Pneumatics Paper appropriately characterizes the 

different studies and data sources. INGAA agrees that it is important to understand the sources 

of methane emissions, how those emissions are measured and reported, what reduction 

opportunities exist (and what is the cost associated with these opportunities). While the 

Pneumatics Paper provides a summary of several sources of information, the paper does not 

reflect the full breadth of valuable information available to EPA on the topic. Further, while the 

studies have been summarized, they are neither compared nor contrasted with each other or with 

other sources of similar information. It would have been valuable for EPA to provide a tabular 

summary that presents the primary results from each study in common engineering units in order 

to identify data gaps and inconsistencies. While it may not have been the intent of the 

Pneumatics Paper to compare or contrast information, such an exercise is necessary to determine 

if a particular study appropriately characterizes the data available. Further, a comparison of the 

studies would help identify conflicts and data gaps in the information. 

Due to the limited comment period, INGAA did not have time to develop a definitive analysis of 

the various studies listed or a list of key studies that were not included. However, more detailed 

discussion below provides examples of data gaps or differences in the primary tools that are 

being used to inform the process (e.g., differences between Subpart W reporting and the National 

Inventory). 

In general, INGAA views the Pneumatics Paper as a summary of some information, but not the 

full range of studies and data sources currently available. EPA’s characterization that the studies 

presented in the paper are pivotal suggests that EPA considers them key to understanding these 

issues. INGAA would caution EPA against placing excessive weight on this limited information 

                                                            

3 See 40 C.F.R. Part 98 (2014). 4

 EPA publishes GHGRP reporting results through its data publication tool, Facility Level Information on 

GreenHouse gases Tool (FLIGHT); see http://ghgdata.epa.gov/ghgp/main.do 5 Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2012, EPA 430-R-14-003 (April 2014). This report 

presents the U.S. national GHG inventory from 1990-2012 for anthropogenic sources (i.e., associated with human 

activity) and is referred to as the “National Inventory” in these comments. The report is updated annually. 6

 This section includes responses relevant to Pneumatics Paper question 1 (emissions studies). 
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since other studies, not referenced in the Pneumatics Paper, may be based on the same or similar 

data sets but reach different conclusions. 

INGAA also urges EPA to elaborate on how it arrived at its cost analysis for mitigation 

measures. Cost estimates are sensitive to assumptions and inherent data inconsistencies. Costs 

vary over time and with location and chosen technology. As presented by EPA, the 2014 study 

by ICF, Economic Analysis of Methane Emission Reduction Opportunities in the U.S. Onshore 

Oil and Natural Gas Industries, (ICF paper)7 appears to be the primary source of information on 

evaluating cost-effective emissions reduction opportunities. However, the ICF paper has several 

limitations such as only including emissions mitigation options for a subset of emission sources, 

only addressing one mitigation technology or work practice for these select sources (i.e., 

alternatives are not addressed), and generally not addressing uncertainties or presenting ranges 

associated with emission mitigation costs and performance. Further, several other sources of 

similar information have not been referenced. In fact, cost-effectiveness has been examined by a 

number of organizations such as the International Petroleum Industry Environmental 

Conservation Association (IPIECA)8

 and the Intergovernmental Panel on Climate Change 

(IPCC).9 Cost effectiveness has also been a topic during the United Nations Framework 

Convention on Climate Change (UNFCCC) events. Given the significance of understanding the 

costs associated with various methane reduction technologies in crafting a comprehensive costeffective reduction strategy, the Pneumatics Paper should expand the discussion to describe more 

fully the body of available information, including key parameters and assumptions that impact 

cost analyses. As an example, the differences between Subpart W data and the National 

Inventory for T&S sources affects the calculation for potential achievable reductions and thus 

have economic analysis implications. 

New sources of information soon will become available that will significantly add to the 

understanding of methane emissions and reduction opportunities in the T&S sector. Specifically, 

the Pipeline Research Council International (PRCI)10 is completing a report summarizing GHG 

emission reduction technologies and work practices applicable to natural gas pipeline 

compressor stations. The PRCI work will identify existing and commercially available GHG 

emission reduction technologies and work practices for pipeline compressor stations, as well as 

identify technologies in development. The report will evaluate technical and economic viability 

of existing and developmental GHG emission reduction technologies and work practices. While 

this report has yet to be released, PRCI has permitted INGAA to acknowledge the draft 

document for the purposes of our comments. More detail on pneumatic emissions reduction 

technologies and costs is provided in comments below. 

                                                            

7 Economic Analysis of Methane Emission Reduction Opportunities in the U.S. Onshore Oil and Natural Gas 

Industries, ICF International, 2014. 8

 Oil and Natural Gas Industry Guidelines for Greenhouse Gas Reduction Projects, March 2007. 

9

 Climate Change 2007, the Fourth Assessment Report (AR4) of the United Nations Intergovernmental Panel on 

Climate Change (IPCC). 

10 The Pipeline Research Council International (PRCI) is the global collaborative research development organization 

of, by, and for the energy pipeline industry. 
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4. Available Emission Studies and Pneumatic Emissions Significance for T&S Facilities11

EPA has asked for comment on the emissions studies included in the Pneumatics Paper, the 

range of emissions, and information on planned or ongoing studies. While there are several 

sources of information on methane emissions from the natural gas system, the two primary 

sources of GHG emission data are the National Inventory and the EPA GHGRP. The EPA 

compiles both a top-down estimate of GHG emissions (i.e., National Inventory activity data uses 

data such as facility count and miles of pipe to estimate emissions) and detailed bottom-up 

reporting (GHGRP). The National Inventory is commensurate with a Tier 1 or Tier 2 estimate 

(i.e., using activity data at the facility or large unit level), while Subpart W of the GHGRP uses 

Tier 3 (more granular source or component level activity data) or Tier 4 (detailed source level 

data or direct measurement) estimates. These two reports use different methods for estimating 

methane releases and do not include all of the same sources of releases. Accordingly, there 

currently is no single compilation that comprehensively and accurately addresses all sources of 

methane released by the T&S sector. 

While the National Inventory and the GHGRP produce consistent estimated emissions from 

some sources (e.g., the natural gas production segment), there are significant differences for the 

other segments of the natural gas system. There likely are multiple reasons for the disparity, 

including differences in the methodologies used in the two programs, and the specific sources 

being measured and included for reporting. For example, EPA updated key National Inventory 

estimates for the production segment based on more recent data, including Subpart W data. In 

addition, the facility definition for production captures nearly all production operations. In 

contrast, EPA has not yet updated its key estimates for the T&S segment, and it does not appear 

that EPA has compiled or analyzed results based on thousands of measurements for T&S sources 

completed in response the GHGRP reporting requirements. INGAA suggests that the approach 

used for production can also be used to improve the estimates for the T&S sector and to serve as 

a more accurate basis for determining costs and mitigation opportunities. Work to reconcile 

these estimates remains an area of needed analysis before drawing any definitive conclusions 

about the total level of methane emissions from natural gas pipelines or definitively addressing 

related questions about mitigation and costs. 

The need for more current data and analysis on methane emission levels is highlighted by the 

fact that most T&S emission factors used for estimating methane emissions are based on a 

limited set of data that is approximately two decades old. The emission factors that are used to 

calculate methane emissions for both the National Inventory Report and for some Subpart W 

sources, have typically been in place since the 1990s and need to be updated. For T&S, the 

National Inventory (and other published papers and studies) primarily rely on emission factors 

derived from an EPA – Gas Research Institute (GRI) study12 that was completed in the early 

1990s and published in 1996. These factors may not accurately reflect natural gas transmission 

methane emissions because operating practices, as well as the efficiency of operating equipment, 

                                                            

11 This section includes responses relevant to Pneumatics Paper questions 1 and 2 (emissions studies and range), and 

3 (mitigation). 

12 Methane Emissions from the Natural Gas Industry, EPA/GRI report (June 1996) at: 

http://www.epa.gov/gasstar/tools/related.html; This 15-volume compendium of reports is from an EPA/GRI study 

published in 1996 that remains a seminal reference on methane releases from natural gas systems. These reports and 

related data are referred to as the “EPA-GRI Study” in this paper. 
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have improved over the past 20 years. INGAA urges EPA to initiate a program to use the T&S 

data from 2011, 2012 and 2013 GHGRP reporting to support development of improved emission 

factors. 

The GHGRP also has some limitations, including reliance on dated emission factors and 

exclusion of smaller facilities and smaller sources at subject facilities. Subpart W also does not 

require reporting of known sources, such as rod packing emissions in “not operatingpressurized” (i.e., standby) mode, and centrifugal compressor emissions from dry seals. 

However, analysis of the reported data should significantly improve the understanding of 

methane emissions from the T&S sector, especially where measurement is required. Future 

improvements in estimates of aggregated methane emissions, along with use of Subpart W direct 

measurements to update emission factors, can lead to more accurate estimates overall. We ask 

that EPA work with the industry to develop emission factors for the sources with new 

measurement data available. 

Contribution of Pneumatic Device Emissions for T&S Facilities13

Review of the Subpart W and National Inventory data indicates significant differences. For the 

transmission segment in 2011, the National Inventory estimate is over 25 times higher than 

Subpart W. This is due in part to the fact that Subpart W considers only a subset of all 

transmission facilities, those facilities with annual emissions greater than 25,000 metric tons CO2

equivalent (CO2e), but this would likely account for only part of the difference. A more accurate 

estimate for the differences based on a “national estimate” using Subpart W data could be 

obtained by using the activity data from the National Inventory (station count) and an emission 

factor based on Subpart W data. The emission factor would be based on dividing the 

transmission segment Subpart W pneumatic emissions by the number of reporting facilities. 

Even using this approach to scale up Subpart W estimates, the National Inventory estimate is 

over four times higher that an estimate based on Subpart W data. Considering the five primary 

T&S sources that report under Subpart W (i.e., reciprocating compressors, centrifugal 

compressors, pneumatic controllers, equipment leaks and blowdowns), pneumatics contribute 15 

percent of the National Inventory for transmission but only 5 percent of the Subpart W inventory. 

It is expected that the relative contribution percentage would remain fairly consistent across all 

T&S facilities, including those that did not trigger reporting under Subpart W. In addition, some 

INGAA members indicated that the portion of pneumatic emissions was even lower. As 

discussed below, Subpart W may include an over-estimate of pneumatic emissions for some 

companies because of a tendency to conservatively count pneumatic devices as a high bleed 

device if the categorization (i.e., actual bleed rate above or below the “high bleed” threshold) 

was not clear. 

In addition, it is possible that the 2011 Subpart W emissions have been over-reported because the 

count of high bleed devices may have been over-reported. The demarcation between high and 

low bleed devices (bleed rate of 6 SCFH) is not founded in pneumatic-device technology but is 

rather an artifact of a limited analysis associated with the device population of a single company. 

There is anecdotal information that indicates operators were conservative in this initial estimate 

and “over-counted” the number of high bleed devices. The classification of high or low bleed is 

                                                            

13 This section includes responses relevant to Pneumatics Paper questions 1 and 2 (emissions studies and range), 5 

(prevalence), and 9 (new studies). 
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based on an engineering estimate using available information, and in many cases, the device 

bleed rate was unknown. Thus, some operators, taking a conservative approach, counted devices 

as high bleed if the classification was not clear. The Subpart W estimate is based on a count of 

pneumatic devices by device type (high bleed, low bleed or intermittent bleed) and an emission 

factor for each of the three device types. The emission factors are based on data from the 1990 

EPA-GRI study. 

Since the emission factors for high bleed and low bleed devices differ by a factor of thirteen, 

undercounting low bleed devices and over-counting high bleed devices would significantly affect 

the pneumatic device inventory. An initial review of Subpart W 2011 data counts by device type 

indicates approximately three times as many high bleed devices as low bleed devices. That is 

not consistent with the common understanding and practices of current operations, in which low 

bleed and intermittent bleed devices are much more common. This further expands the 

difference between the Subpart W inventory and National Inventory, discussed above, and this 

indicates that pneumatic device emissions for compressor stations are a smaller relative 

contributor than indicated by the National Inventory. This disparity should be reconciled to 

ensure that potential reductions and mitigation costs are accurately determined prior to 

developing new regulatory or voluntary programs for these sources. It is possible that T&S 

pneumatic device emissions in practice are significantly lower than estimated in the National 

Inventory and also potentially lower than those reported under Subpart W due to an overestimate of high bleed devices). Thus, these sources may not require further reductions. 

Industry continues to review available information from Subpart W reporting for 2011, 2012 and 

2013, and additional insights may be gained. In addition, T&S sector results from a 

collaborative project that includes several natural gas transmission companies and the 

Environmental Defense Fund (EDF) should be published later this year. That measurement 

program could include additional insight on the relative contribution of pneumatic devices to the 

T&S inventory. 

INGAA has not conducted a survey of operators or tried to identify the reasons for the inventory 

differences, but there are several possible contributing factors based on our understanding of the 

data and discussions with operators, including: 

• The National Inventory T&S emission estimates are based on 20-year-old emissions data; 

• In recent years, T&S operators have switched to lower bleed devices when feasible (e.g., 

through the Natural Gas STAR program); 

• In recent years, pneumatic devices powered by instrument air systems have replaced natural 

gas-driven devices at some facilities where this does not present a pipeline safety risk; and 

• Operators may not have a consistent understanding or interpretation of the three categories of 

pneumatic devices identified as being used within the T&S industry. It would be beneficial 

to have more specific and detailed guidance established for the pneumatic devices used 

within the T&S industry to help eliminate the potential for different interpretations. 

Several questions from the Pneumatic Paper appear to focus on upstream operations rather than 

T&S operations. For example, the white paper references 2013 studies that report a wide range 

of emissions. INGAA understands that additional work may be underway for upstream systems, 

but cannot offer insight into those issues. For the T&S sector, pneumatic pumps common in 

upstream operations are much less prevalent and, accordingly, emissions are expected to be 
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much lower from pneumatic devices in the T&S sector. Further, instrument air systems that may 

be feasible for some compressor stations are not feasible in remote areas that do not have access 

to electric power. 

Finally, the white paper asks about factors that result in different emission rates. As noted above, 

the 6 SCFH threshold used to differentiate high bleed and low bleed pneumatics is based on a 

limited analysis done in the past, and is not based on common technical specifications or design 

criteria. Many devices can emit at a rate above or below this threshold depending on operational 

requirements. Both design and operational factors can contribute to the bleed rate, including 

operational influences such as service or application, supply pressure, proportional setting, 

output pressure range, set point pressure, frequency of use, etc. 

 

5. Mitigation Techniques and Costs14

Pneumatic pumps (e.g., glycol dehydrator Kimray pumps) common in upstream operations are 

not prevalent at T&S facilities. Thus, our comments are focused on pneumatic controllers and 

not pneumatic pumps. The two primary mitigation approaches that are relevant are: (1) use of 

low bleed controllers, and (2) use of instrument air systems. Both are discussed in the 

Pneumatics Paper. As discussed in Section 3 of this document, PRCI is completing a report that 

provides details on compressor station mitigation technologies and work practices, associated 

performance and cost ranges, and factors that influence technical feasibility. That document 

should be available this summer, and may provide insight into mitigation and cost-related 

questions from the Pneumatics Paper. We will look forward to participating in review of other 

technologies and cost information that become available through the PRCI and other reports that 

may be informative on this emissions source. 

At this time, INGAA recommends that differences in the National Inventory and Subpart W 

emission estimates and their underlying methodologies be reconciled so that the contribution of 

pneumatic controllers to the T&S sector emission inventory is appropriately considered in 

mitigation strategies going forward. Additional information on the prevalence of low versus 

high bleed devices and instrument air systems also could be examined to understand how the 

current inventory may be lower than previous estimates. Additional mitigation may not be 

required if the total inventory is relatively small and the use of lower emitting units is prevalent. 

A more refined inventory of pneumatic devices across the T&S sector and the corresponding 

emission estimates should be performed before a thorough analysis of appropriate mitigation 

technologies and associated costs are undertaken. 

INGAA does not have recommendations at this time regarding instrument air systems or electricpowered controllers, although these technologies will likely be included in the PRCI report. As 

noted above, anecdotal information indicates instrument air systems are more prevalent now than 

when pneumatic controller emission estimates were completed for the EPA-GRI study in the 

1990s, but specific information is not available and a survey would be required to provide more 

detail. 

                                                            

14 This section includes responses relevant to Pneumatics Paper questions 3 -through 7 (mitigation techniques, 

costs), and question 9 (new studies). Note that question 8 pertains to pumps, which are not prevalent in T&S 

operations, and therefore is not discussed.
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EPA also asks about applications where natural gas-driven controllers may be required. T&S 

compressor stations use natural gas-driven controllers for the large valves that are used to isolate 

portions of the facility or pieces of equipment. Process control and safety concerns may require 

use of intermittent natural gas-driven pneumatic controllers to provide a fast response with 

enough motive force to actuate a rapid valve response. 

Gas-driven pneumatic controllers at T&S facilities are required for safety reasons. Specific 

pneumatic device examples include, but are not limited to, mainline block valves, emergency 

shutdown valves, pipeline or station manifold isolation valves, pressure relief valves, meters, 

regulators, etc. Natural gas-driven pneumatic controllers are needed to operate these systems to 

ensure consistent and safe operation or closure in emergency situations. Natural gas is needed 

for these applications due to system reliability and safety reasons. Alternative operators driven 

by instrument air, electricity, solar power or other means would not provide the same level of 

safety or reliability. If electrical power service at a compressor station or gas plant is lost, even 

for short, temporary time periods, the systems controlled by these pneumatic devices would not 

be able to operate or close, which could allow pressure build ups potentially causing catastrophic 

equipment failure, pipeline ruptures or explosions. 

Finally, one member company analyzed its Subpart W emissions data reported to EPA under the 

GHGRP. The total GHG emissions from pneumatic devices for that company was 

approximately 1 percent of its total GHG emissions for all Subpart W emission categories. EPA 

should not focus on methane emission reductions from pneumatic devices from the T&S sector 

given the need for gas-driven pneumatic devices for safety and reliability and the extremely low 

GHG emissions from these devices. Other reduction opportunities provide greater methane 

emission reductions with lower effort and cost. INGAA would be glad to discuss other 

opportunities. 

6. Coordinate Methane Initiatives Across Agencies and Establish a Primary Point of 

Contact

As part of the Obama administration’s Climate Action Plan, the Administration has initiated 

several efforts that address methane reductions, including revisions to the EPA Natural Gas STAR 

Program, launch of the Quadrennial Energy Review, revision of EPA’s GHGRP, the five methane 

white papers and plans to revise regulations to control VOC emissions, and possibly methane 

emissions, from the oil and gas sector.15 This level of simultaneous activity on a common issue 

challenges the industry and other stakeholders, and coordination between industry and between 

policymakers is crucial. Therefore, INGAA recommends that the Administration establish a 

primary point of contact responsible for ensuring coordination across the multiple federal agencies 

and departments tasked with methane-related initiatives impacting the T&S sector. Ideally, this 

point of contact would provide guidance and assistance in the development, interpretation and 

implementation of methane policies. It can be difficult for the pipeline industry to manage the 

numerous and sometimes duplicative requests for information from multiple agencies and 

departments. 

                                                            

15 For example, potential revisions to 40 C.F.R., Part 60, Subpart OOOO. 
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As questions arise about the overall climate change strategy, it would be extremely helpful to have 

this same primary point of contact within the Administration to discuss methane and other GHG 

reduction issues, opportunities, and policies. 

7. Conclusion 

INGAA and its members are committed to reducing methane emissions in a prudent and 

environmentally responsible manner. INGAA and its members are undertaking initiatives to 

understand the sources of T&S sector methane emissions and to identify the most significant 

sources and the most cost-effective methane emission reduction strategies. In summary: 

1. EPA should reevaluate whether pneumatics are relevant to the interstate natural gas (T&S 

sector. INGAA submits that pneumatics is an upstream issue and not a significant 

emission source for the T&S sector. 

2. Gas-driven pneumatics are needed for some process applications to address rapid process 

control, possibly due to safety concerns, such as large valves that are used to isolate 

portions of the facility or pieces of equipment. 

INGAA appreciates the opportunity to comment on the Pneumatics Paper and will continue to 

provide EPA with additional information as it becomes available. 

Sincerely, 

Lisa S. Beal 

Vice President, Environment and Construction Policy 

Interstate Natural Gas Association of America 

 
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Appendix A 

Pneumatics Questions and INGAA Response 

1. Did this paper appropriately characterize the different studies and data sources that quantify 

emissions from pneumatic controllers and pneumatic pumps in the oil and gas sector? 

Responses are found in sections three and four of the INGAA comment document. 

2. Please discuss explanations for the wide range of emission rates that have been observed in 

direct measurement studies of pneumatic controller emissions (e.g., Allen et al., 2013 and 

Prasino 2013). Are these differences driven purely by the design of the monitored controllers or 

are there operational characteristics, such as supply pressure, that play a crucial role in 

determining emissions? 

Responses are found in section four of the INGAA comment document. 

3. Did this paper capture the full range of technologies available to reduce emissions from 

pneumatic controllers and pneumatic pumps oil and gas facilities? 

Responses are found in sections four and five of the INGAA comment document. 

4. Please comment on the pros and cons of the different emission reduction technologies. Please 

discuss efficacy, cost and feasibility for both new and existing pneumatics. 

Responses are found in section five of the INGAA comment document. 

5. Please comment on the prevalence of the different emission control technologies and the 

different types of pneumatics in the field. What particular activities require high bleed pneumatic 

controllers and how prevalent are they in the field? 

Responses are found in sections four and five of the INGAA comment document. 

6. What are the barriers to installing instrument air systems for converting natural gas-driven 

pneumatic pumps and pneumatic controllers to air-driven pumps and controllers? 

Responses are found in sections five of the INGAA comment document. 

7. Are there situations where it may be infeasible to use air driven pumps and controllers in place 

of natural gas-driven pumps and controllers even where it is feasible to install an instrument air 

system? 

Responses are found in sections five of the INGAA comment document. 

8. Did this paper correctly characterize the limitations of electric-powered pneumatic controllers 

and pneumatic pumps? Are these electric devices applicable to a broader range of the oil and gas 

sector than this paper suggests? 

No INGAA Response – Not prevalent in the T&S sector. 
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9. Are there ongoing or planned studies that will substantially improve the current understanding 

of VOC and methane emissions from pneumatic controllers and pneumatic pumps and available 

techniques for increased product recovery and emissions reductions? 

Responses are found in sections four and five of the INGAA comment document.