Document pp8rLbOdXXmY1pBL6mpgvZ1NB

April 25, 2017 VIA CERTIFIED AND ELECTRONIC MAIL Ryan Jackson Chief of Staff U.S. FPA Headquarters 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460 Mail Code: 1101A iackson.ryan@epa.gov Deb Thomas Acting Regional Administrator U.S. EPA Region 8 1595 Wynkoop St. Denver, CO 80202-1129 Mail Code: 8RA thomas.debrah@epa.gov Lawrence Starfieid Acting Assistant Administrator - Office of Enforcement and Compliance Assurance U.S. EPA Headquarters William Jefferson Clinton Building 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460 Mail Code:.2201A starfieid.Iawrence@epa.gov Colorado Petroleum Council A Division of API m CZj~I' _o>!, rr 1 -r -fcJ m ZJLT s c Dear Mr. Jackson, Ms. Thomas and Mr. Starfieid: It was with great interest that members of the Colorado Petroleum Council (CPC) read President Trump s March 28 Executive Order Promoting Energy Independence and Economic Growth. We would like to bring to your attention a situation in Colorado that does not appear to conform to this Order, nor the March 2. 2017 Presidential Memo regarding EPA Regional enforcement actions or, for that matter, the principle of cooperative federalism advanced by the President. President Trump's March 28, 2017 Executive Order specifically directs federal agencies to "review all existing regulations, orders, guidance documents, policies, and any other similar agency actions . . . that potentially burden the development or use of domestically produced energy resources, with particular attention to oil [and] natural gas." CPC respectfully requests that EPA conform with this order by pausing the deadlines for the Section 114 request to ensure that they are consistent with the new administration s policy goals. This outcome would be consistent with the emphasis that the President and EPA Administrator have placed on the states' primary role in administering environmental law. These extensive information requests are expensive and time-consuming for the suoject operators, and should be targeted to support policy going forward. These requests, and their associated enforcement actions, could be viewed as a tacit indictment of the regulatory program of the Colorado Department of Public Health and Environment. That program is often cited by the EPA and the environmental community as a model for the nation. In these filings, the EPA alleges violation of Colorado air quality regulations and demands terms of settlement far more stringent than was ever envisioned when the state rules were promulgated. The CDPHE has responded by issuing similar Compliance Advisories to operators responsible for the bulk of the production from the DJ Basin. These Compliance Advisories were filed in parallel with EPA's Section 114 requests so that CDPHE would have a seat at the table. Colorado's rules already include a robust, statewide Leak Detection and Repair (LDAR) program, stringent storage tank emission controls and numerous other requirements designed to minimize emissions. These regulations are appropriately administered at the state level and are the subject of rigorous enforcement by CDPHE. Please be assured that our members strive to achieve a high level of regulatory compliance and environmental protection. We have led development of emission control technology and practices and worked collaboratively to find commonsense solutions for Colorado's environment and economy. We request that EPA Region 8 cease its Section 114 campaign in order to allow states' primacy In administering their environmental programs, as envisioned by federal environmental statutes. Thank you for your time and please feel free to contact me with any questions. Respectfully, fli Uv. Tracee Bentley Executive Director Colorado Petroleum Council 1660 Lincoln St. Suite 2320 Denver, CO 80264 bentlevt@a&i.orq Cc: Mr. Scott Pruitt Ms Suzanne Bohan Ms. Brittany Bolen Ms. Samantha Dravis f f O o O ec2->J 04 <M 3: c/> <d o 0)' <g I|3 *s Dk-- CL S C3tDr OCCDDDX s< lo? 5 Q a, $< t-J CL LU (/) cc</) (1) C e(C/D) 5 ^ Z> ooCN ! 'j 00) Ct I o (M i