IPAA Comments Re: Revisions and Confidentiality Determinations for Data Elements under the Greenhouse Gas Reporting Rule; Docket No. EPA-HQ-OAR-2019-0424

 These comments are filed on behalf of the Independent Petroleum Association of America (IPAA). IPAA represents the thousands of independent oil and natural gas explorers and producers, as well as the service and supply industries that support their efforts, that will be significantly affected by the actions resulting from this regulatory proposal. …

 These IPAA comments will focus on Subpart W for two main reasons. First, it is the Subpart that has the greatest impact on oil and natural gas production. Second, the recently passed Inflation Reduction Act (IRA) fundamentally changed the role of Subpart W emissions factors (EF). Subpart W EF are no longer emissions estimates that can be debated regarding their accuracy; they will be “taxable events” subject to audits, enforcement actions and fines under the Clean Air Act (CAA). Given the history of issues over the accuracy of Subpart W EF, the IRA makes a profound change. …