Gas STAR Gold Program
Public Feedback
The U.S. Environmental Protection Agency (EPA) is requesting feedback from stakeholders on all elements of the
proposed Gas STAR Gold Program, especially the following issues:
(1)	Program Recognition and Incentives
(a)	In addition to recognition through the Program, what are the key incentives for companies to participate
in this enhanced program?
(b)	In addition to recognizing Gas STAR Gold facilities through the EPA web site, conferences, and other
outlets, what are other suggestions or mechanisms for EPA to acknowledge and promote facility Gold-
level achievements?
(c)	How can EPA best market this program to key stakeholders including company management and boards,
state and local regulators, NGOs, investors, shareholders, and the public?
(d)	Are there any suggestions regarding the proposed program name: Gas STAR Gold Program?
(e)	Are there other models or approaches that would be effective at incentivizing voluntary emissions
reductions in this sector?
(f)	How should the program incorporate recognition for actors or partners that are not facilities or oil &
natural gas companies (e.g., public utility commissions or states)?
(2)	Program Implementation
(a)	What facility barriers exist to achieving "Gold" recognition that EPA can assist in overcoming?
(b)	EPA is proposing that facilities would need to achieve 100% implementation of all applicable protocols at
each facility to earn Gas STAR Gold status (with exceptions for safety or emergency situations). We
welcome feedback on other thresholds or mechanisms for achieving Gas STAR Gold status at the facility
level that maintains high levels of integrity, verifiability, and methane emissions reductions.
(c)	EPA seeks feedback on specific aspects of implementing the Program at the facility level including
handling acquisitions and divestitures for the production segment.
(d)	EPA plans to leverage existing data and reporting mechanisms (such as the Greenhouse Gas Reporting
Program) wherever possible. Are there particular ideas or suggestions for EPA to streamline reporting in a
way that reduces burden to the facilities?
(e)	EPA seeks feedback on the proposed frequency of annual reporting for Gas STAR Gold facilities. Would a
rolling reporting system (with a corresponding rolling certification of Gas STAR Gold facilities) be
preferable?
(f)	EPA proposes that companies achieve or exceed Gas STAR Gold status at 90% of their facilities to earn
"Platinum" status. EP A seeks feedback on the proposed threshold for companies to earn this status.
(g)	EPA seeks feedback on the appropriate time frame before a company should submit its Implementation
Plan (e.g., 3 months after submitting Letter of Intent, and annual updates thereafter).
(h)	EPA seeks feedback on the program's provisions for data transparency and verification (e.g., EPA
verification versus third party verification).

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(3)	Existing Regulatory Frameworks
(a) It is the intent of Gas STAR Gold Program to meet or exceed existing voluntary and mandatory methane-
related voluntary and regulatory frameworks. Do any of the proposed protocols conflict with existing
regulations or frameworks?
(4)	Proposed Protocols
(a)	Are appropriate emissions sources targeted in these protocols?
(b)	Are appropriate best management practices, technologies and/or emission mitigation targets used in the
protocols?
(c)	Should EPA consider any additional emissions sources and/or associated protocols?
(d)	EPA seeks feedback on other mechanisms to incentivize facilities to achieve the methane emissions
reductions, especially from the largest sources of methane.
(e)	For the local distribution segment, please provide feedback on performance goals for specific sources,
such as cast iron pipe replacement, that can expedite the pace of methane emissions reductions in the
context of existing regulatory frameworks.
(f)	For local distribution companies with limited or no cast iron or exposed steel pipe, EPA seeks feedback on
how to further methane emissions reductions that would be appropriate for "Gold" recognition.
(g)	Casinghead gas is a large methane emissions source in certain locations. EPA is seeking feedback
regarding the proposed protocols for this source.
(h)	EPA recognizes three major phases in the life of an unassociated gas well when liquids unloading is
necessary; (a) when the reservoir has sufficient energy to lift the liquids with or without a plunger lift
system, (b) when the reservoir has energy, but not sufficient enough to lift a plunger plus a reasonable
liquid load to the sales line; and (c) when the reservoir has insufficient energy to expel liquids by any
means except to pump the liquids separately from gas flow. EPA is seeking feedback on the feasibility of
capturing gas from well liquids unloading in phases (b) and (c) in the life of a gas well.
(i)	For cast iron pipeline and unprotected steel pipeline distribution mains fugitive emissions sources, EPA is
seeking feedback on the feasibility and economics of replacing, lining, or sealing, either internally or
externally, these pipelines to mitigate emissions. EPA is also seeking feedback on the effectiveness of
lining and sealing options in mitigating methane emissions.
(j) EPA has suggested an annual and bi-annual inspection frequency for detecting and fixing fugitive
emissions from onshore production and gathering and boosting facilities based on the absolute tonnage of
natural gas emissions. EPA recognizes that such a requirement automatically requires very large basins to
fall into the bi-annual frequency requirements. Other possible options include but are not limited to
considering using an emissions intensity (emissions divided by production from the facility) approach to
determine the survey frequency.
(k) EPA welcomes feedback on ways in which the program can be designed to foster continual improvement,
i.e., through specific mechanisms and timeframes for assessing the program elements and making
appropriate modifications to the protocols to reflect the evolving industry state-of-the-art.
United States
Environmental Protection
Kb I B %Agency

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