EPA’s Information Collection Request (ICR) to Reduce Future Oil and Gas Emissions

As part of the Paris Climate Conference, U.S. President Barack Obama and Canadian Prime Minister Justin Trudeau committed to new actions to reduce methane pollution from the oil and natural gas sector – the world’s largest industrial source of methane. Methane, a key constituent of natural gas, is twenty-five times more powerful at warming the planet as compared to carbon dioxide and the aspiring goal of reducing methane emissions by 40-45 percent below 2012 levels by 2025 in oil and gas operations will ensure a more stable environment for future generations.

To act on the Barack Obama’s commitment, EPA issued a final Information Collection Request (ICR) that will assist the agency in developing regulations to reduce methane emissions and emissions of other air pollutants from oil and gas sources. ICR will help EPA in identifying the most significant sources of emissions, the kinds of technologies that work best to reduce them, and how those technologies can be applied effectively. There are 2 parts of the information collection request.

• Part 1 Operator Survey: gathers information regarding number and types of equipment at production facilities. This survey is for all oil and natural gas operators and the time to respond to this survey is 60 days.

• Part 2 Facility Survey:  gathers detailed unit specific information on emission sources at specific facilities, as well as emission control devices or management practices used to reduce emissions.  The time to respond to this survey is 180 days.

The response to the ICR is mandatory under Section 114 of the Clean Air Act, hence there is an increased burden of reporting on the oil and gas industry at this time. Also, the widely dispersed workers and sites do not allow activities of every site to be always tracked in a central location, therefore several oil and gas companies will find addressing EPA’s Information Collection Request (ICR) time and labor intensive and some companies might even need to devote additional resources to address it.

Also, this might not be the last information request that oil and gas companies received. In order to easily comply with future requests and stay ahead of the curve, proactive oil and gas company’s operators should start shifting towards centralizing their processes and critical environmental information.

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