Nov 25, 2019 Independent Producers Comments on 9-24-2019 VOC Proposal
Dear Administrator Wheeler:
The following Comments are submitted on the above-referenced proposed rule (Proposed Policy Rulemaking) on behalf of the following national and state trade associations: the Independent Petroleum Association of America (IPAA), American Exploration & Production Council (AXPC), Domestic Energy Producers Alliance (DEPA), Eastern Kansas Oil & Gas Association (EKOGA), Illinois Oil & Gas Association (IOGA), Independent Oil and Gas Association of West Virginia, Inc. (IOGA-WV), Indiana Oil and Gas Association (INOGA), International Association of Drilling Contractors (IADC), Kansas Independent Oil & Gas Association (KIOGA), Kentucky Oil & Gas Association (KOGA), Michigan Oil and Gas Association (MOGA), National Stripper Well Association (NSWA), North Dakota Petroleum Council (NDPC), Ohio Oil and Gas Association (OOGA), The Petroleum Alliance of Oklahoma (The Alliance), Pennsylvania Independent Oil & Gas Association (PIOGA), Texas Alliance of Energy Producers (Texas Alliance), Texas Independent Producers & Royalty Owners Association (TIPRO), and West Virginia Oil and Natural Gas Association (WVONGA) (collectively, Independent Producers). The Independent Producers have participated individually or through the Independent Producers in most, if not all, of the rulemakings and associated litigation since the Environmental Protection Agency (EPA or Agency) proposed to revise the New Source Performance Standards (NSPS) for the Oil and Natural Gas Sector in August 2011. 76 Fed. Reg. 52,738 (Aug. 23, 2011). The Independent Producers support the following aspects of the Proposed Policy Rulemaking:
- EPA should rescind the methane-specific requirements of the NSPS applicable to sources in the production and processing segments;
- EPA should remove sources in the transmission and storage segment from the source category and further evaluate how classes within the existing source category are regulated; and
- EPA should conduct a pollutant specific significant contribution finding before regulating that pollutant from an existing source category.