Comments to the Environmental Protection Agency Office of Inspector General on its Review of EPA’s Estimate of Methane Emissions from Oil and Natural Gas Production

Comments to the Environmental Protection Agency Office of Inspector General on its Review of EPA’s Estimate of Methane Emissions from Oil and Natural Gas Production

In June 2017, the Environmental Protection Agency’s (EPA) Office of Inspector General (OIG) announced that it intended to initiate a preliminary investigation regarding EPA’s estimation of methane emissions from the oil and natural gas production sector. … IPAA’s member companies are significantly affected by the methane emissions and Volatile Organic Compound (VOC) regulations and Control Techniques Guidelines (CTG) that EPA has promulgated over the past several years. A key part of the debate over these regulations relates to their justification – justification that is based on EPA estimates of methane emissions. Throughout this debate, IPAA has been concerned that EPA has overestimated methane and VOC emissions. These overestimations then become critical to the justification of EPA’s regulations; several estimation actions occurred at key times in the regulatory process when the Obama Administration sought to move aggressively to expand federal regulation of oil and natural gas production.

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