2025 EPA Extension of Deadlines Comment Letter

Dear Administrator Zeldin:

The Independent Petroleum Association of America (IPAA) hereby submit these comments on the Environmental Protection Agency (EPA) Interim Final Rule: Extension of Deadlines in Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review.

IPAA represents thousands of American independent oil and natural gas producers across the nation that are most affected by the standards (Subpart OOOOb) and guidelines (Subpart 0000c) promulgated by the EPA, and therefore by the actions addressed in this rule.

Overview

IPAA supports this action by EPA to extend a selection of deadlines regarding regulations under Subparts 0000b and 0000c. This action recognizes that these deadlines are impractical because the agency has accepted that reconsideration of the underlying regulations is essential.

EPA has correctly identified that several specific source requirements – control devices, equipment leaks, storage vessels, process controllers, covers/closed vent systems, and continuous monitoring of the “vent gas net heating value” of flares and enclosed combustion control devices – must be modified. Similarly, state planning requirements and the Super Emitter program need revision. Deadlines associated with these requirements must be adjusted.

Additionally, IPAA believes that the Annual Reporting Deadline requirements that were the subject of specific extensions in early August should be suspended until the final regulatory structure of Subpart 0000b is settled.

While EPA’s regulations represent a reasonable extension of time, when the final regulatory structures of Subparts 0000b and 0000c are completed, EPA should revisit these timelines to confirm they are still adequate. …