Jun 3, 2020 Subpart OOOOa Supplemental Comments
These comments are filed in response to supplemental comments filed on April 13, 2020, by the Environmental Defense Fund (EDF) for itself and several other professional environmental issues advocacy organizations (EDF 2020 Comments). The EDF 2020 Comments address issues that arise in both the EPA 2018 Reconsideration proposal (EPA-HQ-OAR-2017-0483) and the EPA 2019 Proposed Policy rulemaking (EPA-HQ-OAR-2017-0757). Within the EDF 2020 Comments, there are specific issues related to comments provided by the IPAA. As the IPAA has shown in past comments, the EDF 2020 Comments continue to distort analyses of methane emissions as they seek to cripple American oil and natural gas production through the use of federal regulations that are not supported factually or legally justified.
Review of Major Issues
To put these supplemental comments in context, it is important to review the larger framework of debate and background on these issues…