Dec 8, 2017 IPAA and Cooperating Associations Comments to the Environmental Protection Agency on its Proposed Rule and Notice of Data Availability for Emission Standards for New, Reconstructed, and Modified Oil and Natural Gas Sources
Dear Administrator Pruitt: The following comments are submitted on the above-referenced proposed rule and notice of data availability (NODA) 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), Oklahoma Independent Petroleum Association (OIPA), Pennsylvania Independent Oil & Gas Association (PIOGA), Texas Alliance of Energy Producers (Texas Alliance), Texas Independent Products & Royalty Owners Association (TIPRO), and West Virginia Oil and Natural Gas Association (WVONGA) (collectively, “Independent Producers”). We respectively ask that you consider these comments. We are here to respond to any questions or comments you may have.