5900-412 Partnership Agreement for Best Management Practice

EPA’s Voluntary Methane Challenge and Natural Gas STAR Programs

MC BMP Commitment Partnership Agreement_ICR VERSION 2021

OMB: 2060-0722

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OMB Control No. 2060-0722

Approval expires XX/XX/202X

Methane Challenge Program

Partnership Agreement for Best Management Practice (BMP) Commitment

The Methane Challenge Program is a flexible, voluntary partnership between the U.S. Environmental Protection Agency (EPA) and oil and natural gas companies. This voluntary Program allows the EPA to collaborate with Partners to promote and track ambitious, transparent commitments to voluntarily reduce methane emissions beyond regulatory requirements and to recognize Partners for their progress. By signing this agreement,                    (company name) agrees to join the U.S. EPA to reduce methane emissions through a Best Management Practice (BMP) Commitment. The BMP Commitment entails a Partner commitment to company-wide implementation of BMPs to reduce methane emissions from key sources by a future target date. Partners commit to at least one emission source and specify a target year of completion (maximum of five [5] years from commitment start date). Partners should only report on implementation of methane mitigation activities that are not required by, or implemented to comply with, federal, state, or local regulations. If, during a partner’s commitment, methane emissions from a committed source are regulated at the federal, state, or local level, the partner can choose to end its commitment the year before the regulation goes into effect.

EPA’s Responsibilities

  1. Assign a Methane Challenge Program Representative responsible for assisting the Partner in implementing the Program.

  2. Provide relevant Program details, which can be found in the Methane Challenge Program: BMP Framework and Methane Challenge BMP Technical Documents.

  3. Assist Partners with Program implementation by:

  1. providing relevant technical information;

  2. developing a mechanism for reporting supplemental information;

  3. updating Program information as needed, including updating the list of participating sources and mitigation options covered in the Program; and

  4. answering questions about Program participation.

  1. Encourage new and innovative methane emission mitigation technologies, as well as methodologies for monitoring and measuring progress, and incorporate them into the Program.

  2. Track Partner progress with the Electronic Greenhouse Gas Reporting Tool system through which Partners report supplementary data relevant to achieving their Methane Challenge commitments. Supplementary data will be used in conjunction with data that are already collected by Subpart W of the Greenhouse Gas Reporting Program (GHGRP).

  3. Promote the transparency and visibility of the Methane Challenge Program and member commitments and achievements, by publicly releasing non-confidential data that is submitted either through the Methane Challenge Program or through the GHGRP.

  4. Acknowledge Program Partners through announcement of commitments, Implementation Plans, progress, and achievement of goals on the EPA’s Methane Challenge website.

Methane Challenge Partner’s Responsibilities

  1. Designate a company representative as the Methane Challenge Program Implementation Manager responsible for serving as the contact point concerning implementation of this voluntary agreement.

  2. Submit an Implementation Plan within six (6) months of signing this agreement outlining expected activities and milestones for achieving commitments.

  3. Specify commitment start date(s), which will be within six (6) months of joining the Program.

  4. Implement BMPs for the selected participating sources across company operations to achieve mitigation commitments by the specified commitment target year, not to exceed five (5) years from the specified commitment start date.

  5. Report on an annual basis non-CBI supplementary data relevant to achieving Methane Challenge commitments, as outlined in Program documents. Supplementary data will be used in conjunction with data collected by Subpart W of the GHGRP to demonstrate Partner progress within the Program.

  6. Communicate participation to employees.

General Terms

  1. This voluntary partnership is intended to promote and recognize voluntary actions taken by oil and gas companies to reduce methane emissions from their operations. It is understood that Partners to this Program may have operations covered by federal, state, and/or other regulatory requirements. It is anticipated that Partners may achieve their Methane Challenge Program commitments through a combination of voluntarily- and regulatorily-driven actions. Participation in this Program does not in any way change legal obligations of Partners to comply with applicable laws regulations.

  2. This agreement can be terminated by either party at any time, with no notice or penalties and no further obligation. The EPA agrees not to publicize a Partner’s withdrawal from the Program beyond removing the Partner’s name from Methane Challenge website. By setting out a target date on this form the Company does not intend to expose itself to regulatory liability if it cannot meet the target date.

  3. The Partner agrees that the activities it undertakes connected with this Partnership Agreement are not intended to provide services to the federal government and that the Partner will not seek compensation from a federal agency.

  4. The Partner agrees that it will not claim or imply that its participation in the Program constitutes the EPA approval or endorsement of anything other than the commitment to the Program. The Partner cannot use or appropriate the EPA seal or identifier in any way.

  5. In order to maintain status as a Partner in the Methane Challenge Program, the Partner agrees to annually report specified supplemental data, per Program reporting specifications.

  6. If the Partner is unable to meet a BMP commitment by the target year, and intends to remain in the Program, the Partner company will provide relevant contextual information for the delay and set a new target year. The EPA will note the adjustment to the implementation timeline on the Methane Challenge website.

  7. All commitments made by the EPA in this Partnership Agreement are subject to the availability of appropriated funds. Nothing in this Partnership Agreement, in and of itself, obligates the EPA to expend appropriations or to enter into any contract, assistance agreement, interagency agreement, or incur other financial obligations that would be inconsistent with Agency budget priorities. This Partnership Agreement does not exempt the Partner from the EPA policies governing competition for assistance agreements. Any transaction involving reimbursement or contribution of funds between the parties to this Partnership Agreement will be handled in accordance with applicable laws, regulations, and procedures under separate written agreements.

  8. Regarding privacy of the information provided, any contact information for company representatives is used to identify the point of contact for implementation of the Natural Gas STAR Methane Challenge Program. Such information will only be used to communicate and coordinate with Partner companies about their participation in the Natural Gas STAR Methane Challenge Program, such as annual reporting, attending upcoming Program workshops, and progress on their Program commitments. However, some information may be made available to public as required by the Freedom of Information Act, 5 U.S.C. § 552.



Partner’s Best Management Practice Commitment(s)

Please specify initial participating sources, start date, and target achievement year in the table below; check all that apply. For companies joining at the corporate level that wish to make separate commitments for each of their subsidiaries/LDCs, please use “Appendix A: Commitment Table” found on the Methane Challenge Program website and submit in conjunction with this Partnership Agreement.


Source

Start Date

Achievement Year

Onshore Production

Pneumatic Controllers

     

     

Equipment Leaks/Fugitive Emissions

     

     

Liquids Unloading

     

     

Pneumatic Pumps

     

     

Fixed Roof, Atmospheric Pressure Hydrocarbon Liquid Storage Tanks

     

     

Continuous Improvement Source (TBD)

     

     

Continuous Improvement Source (TBD)

     

     

Gathering and Boosting

Pneumatic Controllers

     

     

Equipment Leaks/Fugitive Emissions

     

     

Pneumatic Pumps

     

     

Fixed Roof, Atmospheric Pressure Hydrocarbon Liquid Storage Tanks

     

     

Reciprocating Compressors - Rod Packing Vent

     

     

Centrifugal Compressors - Venting

     

     

Continuous Improvement Source (TBD)

     

     

Continuous Improvement Source (TBD)

     

     

Natural Gas (NG) Processing

Reciprocating Compressors - Rod Packing Vent

     

     

Centrifugal Compressors - Venting

     

     

Continuous Improvement Source (TBD)

     

     

Continuous Improvement Source (TBD)

     

     

NG Transmission & Underground Storage

Reciprocating Compressors - Rod Packing Vent

     

     

Centrifugal Compressors - Venting

     

     

Equipment Leaks (Compressor Blowdown and Isolation Valves)

     

     

Transmission Pipeline Blowdowns between Compressor Stations (Commitment Rate:      ; must be 50% or greater)

     

     

Pneumatic Controllers

     

     

Continuous Improvement Source (TBD)

     

     

Continuous Improvement Source (TBD)

     

     

NG Distribution

M&R Stations/City Gates

     

     

Mains – Cast Iron and Unprotected Steel (Commitment Rate:      )

     

     

Services – Cast Iron and Unprotected Steel

     

     

Distribution Pipeline Blowdowns (Commitment Rate:      ; must be 50% or greater)

     

     

Excavation Damages

     

     

Renewable Natural Gas

     

     

Continuous Improvement Source (TBD)

     

     

Continuous Improvement Source (TBD)

     

     

Signatures and Partner Contact Details

Authorized Company Representative:

      (name)

Signature:


Date:

     


Authorized U.S. EPA Representative: Paul M. Gunning, Director, Climate Change Division

Signature:


Date:

     

Partner’s Designated Methane Challenge Implementation Manager:

Name:

     

Title:

     

Address:

     

City/State/Zip:

     

Telephone:

     

E-mail:

     

Instructions

Please complete this form, including the Authorized Company Representative signature. Email the completed form to the Methane Challenge Program at: [email protected]. EPA will countersign the agreement and email a copy back to the Implementation Manager.

Methane Challenge Partners may make changes to their participation in the program as follows:

To change a commitment: Please submit an updated implementation plan, with the new commitments indicated, to [email protected]. The partnership agreement does not need to be resubmitted.

To change an implementation manager: Please send an email to [email protected] with the new implementation manager’s information. The partnership agreement does not need to be resubmitted.

Methane Challenge Logo Use Guidelines

A high-resolution version of the program logo will be sent to you along with your countersigned partnership agreement. Please visit the Methane Challenge website for guidelines on how partners may, and may not, use the Methane Challenge logo: https://www.epa.gov/natural-gas-star-program/logo-and-brand-guidelines


This collection of information is approved by OMB under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. (OMB Control No. 2060-0722). Responses to this collection of information are voluntary 42 USC 7403(g). An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The public reporting and recordkeeping burden for this collection of information is estimated to be 10 hours per response. Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates and any suggested methods for minimizing respondent burden to the Regulatory Support Division Director, U.S. Environmental Protection Agency (2821T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the completed form to this address

EPA Form No. 5900-412 Document last updated: 31 March 2021 Page 1

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