Council Calls on EPA to Appropriately Regulate Methane

On May 17, 2013, Clean Air Council along with Clean Air Task Force, Sierra Club, Earthworks, Center for Biological Diversity, Kentucky Environmental Foundation, Western Environmental Law Center, Clean Water Action, Group Against Smog & Pollution, and Appalachian Mountain Club submitted comments to the U.S. Environmental Protection Agency (EPA) on its “Proposed 2013 Revisions to the Greenhouse Gas Reporting Rule and Proposed Confidentiality Determinations for New or Substantially Revised Data Elements.”
On April 2, 2013, EPA proposed amendment to the Greenhouse Gas Reporting Rule (GHG RR) to revise global warming potentials (GWPs) for greenhouse gases (GHGs). EPA proposed to use the Intergovernmental Panel on Climate Change (IPCC) values in the Fourth Assessment Report (AR4). EPA also proposed adding GWPs for certain fluorinated GHGs. Emitters use the GWP values in the Greenhouse Gas Reporting Rule to calculate their emissions of GHGs, and to determine whether they are required to report their GHG emissions.
Clean Air Council generally supports updating the GWP values, but has some concerns:
  • While updating the GWP values is commendable, EPA’s previous GWP values were entirely outdated. EPA’s GWP values were based on IPCC’s Second Assessment Report, published in 1995. While two IPCC reports have since been published, (the Third Assessment Report and AR4), this is the first update to GWP values EPA has proposed since the GHG RR was finalized. The AR4, published in 2007, contains the GWP values EPA now seeks to adopt. IPCC is expected to publish the Fifth Assessment Report (AR5) later this year. EPA must continue to update GWP values as climate science advances to most accurately assess the impacts of GHGs. EPA should amend the GHG RR to adopt the GWP values in the AR5, as well as subsequent IPCC reports.
  • EPA must change the reporting time horizon for methane (CH4) from 100 years to 20 years to most accurately assess methane’s contribution to climate change. Because methane is active in the atmosphere for only 12 years, a 20-year time horizon represents methane’s effects on climate change more accurately than a 100-year time horizon.
CAC GHG Reporting Revision Comments.pdf171.34 KB
CATF, Sierra Club et al Comments on GHG Reporting Rule Revisions (1).pdf171.67 KB