Today, IPAA sent a letter to Valerie Jarrett, Senior Advisor to the President, regarding the Office of Information and Regulatory Affairs’ (OIRA) review of EPA’s proposed rulemaking on New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants for the Oil and Gas Sector (NSPS rule).
IPAA Vice President of Government Relations Lee Fuller expressed his concern that the proposed rules, which affect all natural gas wells that are fractured, would especially burden smaller independent producers, “who do not have the same emissions profile as their larger counterparts.”
In addition to issues regarding the quality of the emissions information used in developing the rule and scope of its applicability to fractured wells that emit low volumes of volatile organic compounds, IPAA raised specific issues affecting smaller producers. First, the requirements for fractured natural gas wells would apply to wells that are not hydraulically fractured – wells that cannot use the proposed technology. Second, the requirements for oil storage vapor recovery could be applied to tanks that serve existing marginal well fields. These requirements are far different than the assumptions used to create the proposed rule.
“Simply put, the proposed NSPS does not meet the requirement of the Clean Air Act … the technology is neither cost effective nor adequately demonstrated.”
To read the full letter, please click here.