IPAA and AXPC Joint Comments to the Environmental Protection Agency on its Advance Notice of Proposed Rulemaking on Hydraulic Fracturing Chemicals and Mixtures Under the Toxic Substances Control Act

IPAA and AXPC Joint Comments to the Environmental Protection Agency on its Advance Notice of Proposed Rulemaking on Hydraulic Fracturing Chemicals and Mixtures Under the Toxic Substances Control Act

The American Exploration and Production Council (AXPC) and Independent Petroleum Association of America (IPAA) appreciate the opportunity to provide input and comment on the Environmental Protection Agency’s (EPA’s) Advanced Notice of Proposed Rulemaking (ANPR) under 40 CFR Chapter I, Subchapter R, under the Toxic Substances Control Act (TSCA) on Hydraulic Fracturing Chemicals and Mixtures, published May 19, 2014 . While the ANPR is broad in scope and in information requested, these comments will focus specifically on three specific areas: that (1) due to the availability of FracFocus and other authorities, there is no demonstrated necessity for EPA to use TSCA authority to acquire the information discussed in the ANPR, (2) without such necessity TSCA does not authorize new reporting requirements and (3) TSCA should not apply to the use of chemicals in fracturing because producers are not putting the products into commerce.

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