Multi-Association Comments to the Environmental Protection Agency on its Notice of Proposed Withdrawal of the Control Techniques Guidelines for the Oil and Natural Gas Industry

Multi-Association Comments to the Environmental Protection Agency on its Notice of Proposed Withdrawal of the Control Techniques Guidelines for the Oil and Natural Gas Industry

In proposing withdrawal of the Control Techniques Guidelines for the Oil and Natural Gas Industry (CTG), EPA states: “On June 5, 2017, the EPA granted reconsideration in regard to additional provisions of the 2016 NSPS1. Pursuant to those actions, the EPA is currently looking broadly at the 2016 NSPS. In light of the fact that the EPA is reconsidering the 2016 NSPS and because the recommendations made in the CTG are fundamentally linked to the conclusions in the 2016 NSPS, the EPA believes it is prudent to withdraw the CTG in its entirety. The EPA also believes that the withdrawal will be more efficient for states in revising their state implementation plans (SIPs).” We strongly support EPA’s proposed action for this and other reasons.

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