Good evening. My name is John Walliser and I am with the Pennsylvania Environmental Council. I want to thank the Department for hosting public meetings and accepting comment for implementation of the Federal Subpart OOOOc Emissions Guidelines for Greenhouse Gas Emissions from Existing Crude Oil and Natural Gas Facilities.
This is an issue that speaks to both Pennsylvania’s needs and strengths.
With respect to need, as the second largest producer of natural gas in the country, and with the rise of new energy demand driven by the proliferation of data centers, the importance of addressing methane emissions is essential. Methane emissions harm the environment as a potent greenhouse gas and hurt consumers by wasting marketable product.
As to strength, producers in the Appalachian Basin and here in Pennsylvania are already investing in these control technologies and outperforming their counterparts in other parts of the country. In other words, the requirements won’t curtail any advantage for Pennsylvania. And it aligns with already in-place methane intensity requirements of trading partners like the European Union. Beyond social license considerations, at home and abroad, it’s just good business.
Given that the federal rule was drafted with considerable input from, and support by, industry, Pennsylvania’s implementation is more than meeting the minimum – it’s also meeting the moment by implementing protections for the public while aligning with industry advancement.
We do have one recommendation. Implementation should be done as a rulemaking instead of incorporating the federal provisions into existing permit requirements. The assurance of durability for these protections, as well as establishing predictability for industry through regulation, benefits all sides. It also gives the Department greater opportunity to tailor its implementation to best safeguard the public and provide flexibility for compliance. As noted in the proposed State Plan, the Department already has the authority under the Air Pollution Control Act, and will likely have sufficient time given anticipated deadline extension by the Environmental Protection Agency.
We urge the Department to implement a strong and certain path forward for all parties, and to help ensure our state’s future leadership in energy and environmental protection.
Thank you for your consideration.