Jun 17, 2019 Supplemental Comments Re: EPA’s Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Reconsideration
Dear Administrator Wheeler:
The following Supplemental Comments are submitted on the above-referenced proposed Reconsideration Rulemaking (“Reconsideration Rulemaking”) 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 Producers & Royalty Owners Association (“TIPRO”), and West Virginia Oil and Natural Gas Association (“WVONGA”) (collectively, “Independent Producers”). The Independent Producers have participated individually or through the Independent Producers in most, if not all, of the rulemakings and associated litigation since the Environmental Protection Agency (“EPA” or “Agency”) proposed to revise the New Source Performance Standards (“NSPS”) for the Oil and Natural Gas Sector in August 2011. 76 Fed. Reg. 52,738 (Aug. 23, 2011).1 While many of the Independent Producers represent companies that engage in large volume hydraulic fracturing with horizontal legs, often referred to as unconventional drilling, a significant portion of their membership is also comprised of smaller, family run operations that engage in some form of hydraulic fracturing, involving vertical wells without horizontal legs, referred to as conventional oil or natural gas wells. Many of the individual members constitute small businesses under the Small Business Regulatory Enforcement Fairness Act of 1996.
These supplemental comments are filed by the Independent Producers in response to initial comments and supplemental comments filed by others, including some that directly address the Independent Producers initial comments (filed December 17, 2018).