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
