Letter to the U.S. Environmental Protection Agency Requesting an Extension for Public Comment on its Proposed Information Collection Request for Oil and Gas Facilities

Letter to the U.S. Environmental Protection Agency Requesting an Extension for Public Comment on its Proposed Information Collection Request for Oil and Gas Facilities

The Independent Petroleum Association of America (IPAA) requests a 60 day extension on the initial comment period related to the Information Collection Request for Oil and Gas Facilities. IPAA requests this extension because the current comment period is too short for industry professionals to analyze the complexities of an Information Collection Request (ICR) given the simultaneous requirement to develop implementation plans for compliance with Subpart OOOOa that results from its formal promulgation. However, it is also too short for the Agency to address many issues that it needs to consider before initiating the ICR.