Aug 2, 2016 IPAA and Multi-Trade Association Letter to Environmental Protection Agency Administrator Gina McCarthy Requesting Administrative Reconsideration on its Final Rule on Methane Emissions for the Oil and Natural Gas Sector
A number of industry trade associations hereby submit this petition for administrative reconsideration of the final rule entitled “Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources,” published at 81 Fed. Reg. 35824 (June 3, 2016) (“Subpart OOOOa” or “Methane NSPS”). We request that you take the time to review what and who these trade associations represent and not simply jump to the issues we are seeking reconsideration of. Many of these trade associations have been around since or before the 1950s. The trade associations represent the “independent” exploration and production companies – from the “mom and pop” operations to some of the larger producers in the country – but that is all they do and it is all they know. Subpart OOOOa, as finalized, will have a disproportionate impact on independents and especially independents that constitute “small business” under the Regulatory Flexibility Act.