IPAA and AXPC Joint Comments to the Environmental Protection Agency Regarding its Proposed Information Collection Request for Voluntary Survey to Support the Clean Water Act Hazardous Substances Discharge Prevention and Containment Rule

IPAA and AXPC Joint Comments to the Environmental Protection Agency Regarding its Proposed Information Collection Request for Voluntary Survey to Support the Clean Water Act Hazardous Substances Discharge Prevention and Containment Rule

Dear Mr. Beaman: The American Exploration & Production Council (AXPC) and the Independent Petroleum Association of America (IPAA) are pleased to submit comment to the Environmental Protection Agency (EPA) on its voluntary information collection request (ICR) proposal, “Survey on Clean Water Act Hazardous Substances and Spill Impacts” published in the federal register on September 21, 2017 (Document No. 2017-20170). AXPC and IPAA member companies are currently subject to the existing spill prevention, control, and countermeasure (SPCC) regulations in addition to the many similar, supplementary state specific requirements. As such, AXPC and IPAA believe that the current regulatory environment is sufficient as it provides for adequate protection against any unplanned release of hazardous substances and submits the following response.

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