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View Diary: President Obama can and must take serious action on climate change with and without Congress (160 comments)

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  •  That is a distinction without a difference (1+ / 0-)
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    Roger Fox

    The effect of that NESHAPs rule it to force either collecting well head-released gases during well completion operations and either directing it to distribution systems or flaring the methane of pipeline distribution is not available.  

    Such practices  require methane control even if no methane emission limitation is set.   A methane emission limitation is not needed to achieve control of the methane if the NESHAPs emission limitations applying to hazardous air pollutants (HAPs) result in physical controls that restrain methane emissions in the same manner as the HAP emissions which are the subject of the NESHAPs standard.

    You are confusing EPA's statement about not 'regulating methane' by not providing a methane emission limitation even though methane is quite effectively controlled in practice....   That statement by EPA is there because the NESHAPs rule statutory authority does not reach methane which is not a hazardous air pollutant under the Federal Clean Air Act.

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