Beware The Camel's Nose Under The Tent

EPA's New Climate Enforcement Policy and Third-Party Monitoring Program

Is EPA's new third-party methane super-emitter monitoring and reporting program the camel's nose under the tent?

In the classic fable, on a cold night, a camel asks his owner if he could put his nose inside the owner's tent to keep warm; and through a series of seemingly modest incremental requests, the camel ends up entirely in the tent, displacing the owner to the cold outside. This tale counsels us to be wary of seemingly small (even benign) incremental actions that could grow to create even larger issues, with more significant consequences, down the road.

Far from an incremental or benign action, EPA's new methane rules for the oil and natural gas sector (see 40 CFR Part 60, Subpart OOOOb) authorize certified third parties to report to EPA potential "super-emitter events" which entail methane emissions of 100 kg/hr (220.5 pounds per hour) or greater. This new program allows EPA to