Document vB0nwbn85dgJz80qb0VXqM4eb
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Lee Fuller [lfuller@ipaa.org] 10/3/2017 9:04:30 PM Schwab, Justin [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=eed0f609c0944cc2bbdb05df3al0aadb-Schwab, Jus] James D. Elliott {jelliott@spilmanlaw.com) [jelliott@spilmanlaw.com]; Kern, Gretchen (Gretchen.Kern@pxd.com) [Gretchen.Kern@pxd.com]; Schaaff, Lesley [lschaaff@hess.com]; Susan Ginsberg [sginsberg@ipaa.org]; Samantha McDonald [SMcDonald@ipaa.org] IPAA Meeting Follow Up IPAA Comments - Evaluating Existing Regulations - Docket ID EPA-HQ-OA-2017-019 05-15-2017.pdf; IPAA-AXPC Comments on 9-18-2015 Oil and Gas Proposals.pdf; IPAA-AXPC-Coalition Petition for Reconsideration of Subpart 0000a.pdf; Manipulating Data to Create the Illusion That Low Producing Wells Are Super-Emitters.pdf; Texas Environmental Law Meeting - Environmental Issues in the Oil Patch - 08-2017.pdf
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Follow up
Justin,
We appreciated meeting with you and Mandy yesterday regarding air emissions management of oil and natural gas production operations. I have attached several documents that expand on the nature of the issues that we discussed. There will be some repetition because the issues have been addressed several times.
They include:
1. IPAA comments to EPA on Evaluating Existing Regulations 2. IPAA-AXPC Comments on the Subpart 0 0 0 0 a , CTG and Source Determination
proposals in 2015 3. IPAA-AXPC-Coalition Petition for Reconsideration of Subpart 0 0 0 0 a - includes
the low production well issue among others 4. An assessment of the data manipulation in the study that EPA used to eliminate
the low production well exclusion from Subpart 0 0 0 0 a 5. A publication that I prepared for a meeting on environmental issues in the oil
patch that uses the development of the air emissions regulations as its focus beginning with Subpart 0 0 0 0 .
Thanks again for the opportunity to meet on these issues.
Lee Fuller
Sierra Club v. EPA 18cv3472 NDCA
Tier 2
ED 002061 00162812-00001