The U.S. Environmental Protection Agency (EPA) also announced a proposal in November 2021 to significantly reduce methane emissions from new and (for the first time) existing oil and gas sources across the U.S.. UPA held a special webinar on the rule in November, and many thanks to Jenn Biever from the law firm Williams Weese Pepple & Ferguson for her expertise in efficiently unpacking this very comprehensive proposal. While the proposed rule is far too extensive to summarize here, details are available at: https://www.epa.gov/ newsreleases/us-sharply-cut-methane-pollution-threatens-climateand-public-health. UPA recognizes the importance of reducing methane emissions in key emitting sectors, including energy, as part of a comprehensive strategy to address the risks of climate change. We support cost-effective policies and direct regulation that achieve methane emission reductions from new and existing sources across the supply chain. We believe policy should encourage innovation; incentivize the development and deployment of technologies to monitor and mitigate methane emissions for compliance purposes; allow flexibility; appropriately quantify and assess the feasibility, costs and benefits of implementing new requirements for existing facilities; and properly interpret and follow the relevant provisions of the Clean Air Act. We also recognize that methane emissions and VOC/NOx emissions needed to reduce ozone go hand in hand, with potential overlaps and interactions between the proposed EPA OOOO rules and the efforts and rulemakings associated with the Basin ozone SIP. While regional, national and other trade groups that we regularly collaborate with will be commenting on general provisions of the proposal that apply to industry across the board, UPA’s comments will focus on Utah specific issues, some of which include: • Special consideration needs to be given to retain and align with Utah’s Permit by Rule • We encourage EPA to finalize the Uinta Basin ozone nonattainment FIP for sources located on Tribal lands as expeditiously as possible and recognize the interplay between the newly proposed OOOO rules and the FIP • Impact on small businesses, which includes UPA member companies, and ways to accomplish the stated objectives while minimizing significant economic impacts of the proposed rule • Labor and supply chain shortages that must be considered in terms of implementation requirements • The limited electrification of the basin and challenges to further expanding grid connectivity and capacity We are also collaboratively engaging with DAQ in preparing for a Wasatch Front ozone SIP and the associated rulemakings needed. We continue to remain active in understanding the science and modeling driving these rulemakings and encourage a data-driven approach to policymaking. If you would like to learn more about these important rulemakings along the Wasatch Front and in the Uintah Basin, you are welcome to join UPA and engage in our committees tackling these issues in detail. We believe policy should encourage innovation; incentivize the development and deployment of technologies to monitor and mitigate methane emissions for compliance purposes; allow flexibility; appropriately quantify and assess the feasibility, costs and benefits of implementing new requirements for existing facilities; and properly interpret and follow the relevant provisions of the Clean Air Act. 17 UPDATE
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