AXPC Files Comments on EPA’s Proposed Changes to Subpart W GHG Reporting

WASHINGTON – October 3, 2023 – AXPC filed comments this week on EPA’s proposed revisions to Subpart W (oil and natural gas systems) of its Greenhouse Gas Reporting Rule, outlining significant concerns with the Proposal, acknowledging the Agency’s direction from Congress under the Inflation Reduction Act (IRA) to revise Subpart W, and expressing a desire to work collaboratively with EPA on a highly credible and robust GHG inventory.

“Updating quantification methodologies is important to improving the accuracy and completeness of greenhouse gas reports for the oil and gas industry and we are committed to working with EPA to refine the calculation, estimation, and measurement methodologies set forth by Subpart W, but we have significant concerns with the Proposal as drafted,” said AXPC CEO Anne Bradbury.

AXPC’s comments provided detailed suggestions on the following themes:

  • EPA’s Proposal falls short of incorporating available, credible empirical data for all sources to inform the most accurate calculation of methane emissions. And, as currently proposed, there is risk of double counting, overestimating, or misrepresenting emissions in a way that could show higher domestic emissions than from other international sources – even when, in fact, the opposite is true.
  • EPA should ensure its proposed definitions in Subpart W are consistent with other federal regulatory approaches to avoid burdensome fee implications that may have unintended consequences (such as regulatory uncertainty/ambiguity leading to business risk), since the proposed changes would introduce additional complexity in terms of the calculation methodology hierarchy, with significantly more onerous measurement requirements for certain source categories.
  • EPA should merge this rulemaking with its forthcoming rulemaking to implement the IRA’s Methane Emissions Reduction Program (MERP) emissions charge fee, to ensure that the Agency and all stakeholders can provide maximally informed comment on these two interrelated aspects of EPA’s implementation of the IRA.

“If these areas remain unaddressed, this Rule could hamper the use of empirical data—something Congress, stakeholders, and industry all support —and in some instances may inadvertently incentivize operational practices to actually increase emissions. To avoid these unintended consequences, it is imperative that the Final Rule allow for credible empirical data and be clearly written and aligned with best industry operating practices, as well as EPA and Congressional intent,” said Bradbury.

AXPC members understand the importance of ensuring positive environmental and public welfare outcomes and responsible stewardship of the nation’s natural resources. The United States is a world leader in oil and natural gas production, achieving that status while at the same time substantially reducing emissions. The historic reductions in US greenhouse gas (GHG) emissions over the last decade have been driven by the emergence of US natural gas production as a low-cost source of reliable energy. It is important that regulatory policy enables us to build on that success. AXPC members support continued progress on both fronts through innovation and collaboration.

AXPC’s full comments are available on our website, here.  

About the American Exploration and Production Council:
AXPC is a national trade association representing leading independent oil and natural gas exploration and production companies in the United States. We lead the world in the cleanest and safest onshore production of oil and gas, while supporting millions of Americans in high-paying jobs and investing a wealth of resources in our communities. Learn more at .


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