Ms. Hambrick: The U.S. Chamber of Commerce (the “Chamber”) appreciates the opportunity to comment on the U.S. Environmental Protection Agency’s (“EPA”) “Proposed Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review,” dated November 15, 2021 (the “Proposal”).1 The Chamber supports the smart, balanced regulation, consistent with law, of methane emissions from the oil and gas sector, as an important element of the nation’s overall commitment to continue reducing its greenhouse gas (“GHG”) emissions. Affordable, domestically produced natural gas has been one of the primary driving forces behind significant reductions in carbon emissions achieved over the past decade, most notably from the power generation sector.
Accordingly, the Chamber offers the following comments to help refine EPA’s Proposal to create durable, long-term regulatory certainty for the upstream and midstream segments of the oil and gas sector, while maintaining a proper balance with key economic, legal, and policy considerations. As discussed more fully below, EPA’s proposed regulations should work to achieve additional progress in cost-effectively reducing methane, in accordance with law, while accounting for the key policy considerations described below.