Document ddJLGXG2Q8gE257JbJRyBxGG

Message From: Sent: To: Subject: Attachments: Lee Fuller [lfuller@ ipaa.org] 12/21/2017 9:32:29 PM Schwab, Justin [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=eed0f609c0944cc2bbdb05df3al0aadb-Schwab, Jus] EPA Oil and Natural Gas Production Regulations - Low Producing Wells IPAA-AXPC Coalition Comments on NODA w ith Attachments.pdf Justin, In the past, I've sent you various comments that IPAA has filed on the EPA methaneA/OC regulatory package - NSPS Subparts 0 0 0 0 and 0 0 0 0 a and Control Techniques Guidelines for existing oil and natural gas production facilities in Ozone Nonattainment areas. Attached here are comments submitted on the recent EPA Notice of Data Availability proposal to alter compliance dates on several elements of Subpart 0 0 0 0 a . In general, these comments support EPA's proposal to extend compliance deadlines. One that is addressed specifically is the fugitive emissions program. In particular, the comments address the implications of EPA's decision to apply the requirements to low producing wells (15 b/d and less of oil; 90 mcfd of natural gas) after initially proposing an exclusion for these wells. Part of the issue with EPA technology and cost effectiveness determinations for the fugitive emissions program, which also applies to other requirements but less clearly, involves understanding the differences between production operations when wells are large producers and when they are low producing wells. EPA bases its analyses on large production facilities. However, because the fugitive emissions program places a perpetual cost on the operation, the cost effectiveness is very different when the well is new - at 5000 mcfd, for example - than it is when at the average low producing well rate of 22 mcfd. EPA has the authority under the Clean Air Act to create subcategories when it structures NSPS. The oil and natural gas production industry is a good example of when it should use this authority. Technology and cost effectiveness determinations should be based on realistic operating conditions and the economics of these low producing wells. IPAA would recommend that EPA - as it revisits the methaneA/OC regulations for oil and natural gas production facilities - creates a low producing well subcategory. In early 2018, I'd like to discuss this concept and how to approach it with you. Thanks, Sierra Club v. EPA 18cv3472 NDCA Tier 2 ED 002061 00161302-00001 Lee Fuller Sierra Club v. EPA 18cv3472 NDCA Tier 2 ED 002061 00161302-00002