Document qa9Qd5QzyneLG06J0BY00nkMj

Message From: Sent: To: CC: Subject: Woods, Clint [/0=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=BC65010F5C2E48F4BC2AA050DB50D198-WOODS/ CLIN] 4/4/2018 10:12:35 PM Lee Fuller [lfuller@ ipaa.org]; Gunasekara, Mandy [/o=ExchangeLabs/ou=Exchange Adm inistrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=53dla3caa8bb4ebab8a2d28ca59b6f45-Gunasekara,]; Schwab, Justin [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=eed0f609c0944cc2bbdb05df3al0aadb-Schwab, Jus] James D. Elliott (jelliott@ spilm anlaw.com ) [jelliott@ spilmanlaw.com] RE: Subpart 0 0 0 0 a Lee, Thanks so much for your email, and apologies for the delayed follow up. We are taking a closer look at the attachment, and would welcome the chance to discuss further when convenient. I've copied Emily Atkinson, who may be able to help us in finding a good date/time. Clint Woods Deputy Assistant Administrator Office of Air and Radiatimi, U.S. EPA 202. 564.6562 From: Lee Fuller [mailto:lfuller@ipaa.org] Sent: Monday, April 2, 2018 11:30 AM To: Woods, Clint <woods.clint@epa.gov>; Gunasekara, Mandy <Gunasekara.Mandy@epa.gov>; Schwab, Justin <Schwab Justin@epa.gov> Cc: James D. Elliott (jelliott@spilmanlaw.com) <jelliott@spilmanlaw.com> Subject: Subpart 0 0 0 0 a On March 13, IPAA, several state based trade associations and several member companies met with EPA staff at Research Triangle Park to discuss our concerns with the current structure of Subpart 0 0 0 0 a . While the discussion addressed a number of issues, most of it focused on various definitions that create the scope of the application of the regulations, the fugitive emissions monitoring program and decisions related to the treatment of low production wells. We provided the attached document at the meeting; it is principally addressing the nature of the industry and the role of low production wells including material that responds to published statements by EPA regarding its decision to remove the proposed exclusion of low production wells from the fugitive emissions monitoring program. These include a response to the Environmental Defense Fund allegations that low production wells are "super emitters" and EPA's use of component counts in justifying the inclusion of low production wells. Clearly, there are other policy issues that we would like to address, too. I would like to suggest a meeting to bring these before you in the near future. Thanks, Lee Fuller Sierra Club v. EPA 18cv3472 NDCA Tier 2 ED 002061 00162468-00001