Jul 2, 2018 Comments to the U.S. Environmental Protection Agency on its Draft Audit Policy Agreement for New Owners of Oil and Natural Gas Exploration and Production Facilities
Dear Deputy Director Chapman: This document provides comments from the IPAA in response to the U.S. Environmental Protection Agency’s (“EPA’s” or “the Agency’s”) request for comments on its proposed changes to EPA’s 2000 policy titled “Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations” (the “Audit Policy”) for new owners of oil and natural gas exploration and production facilities and, in particular, the Agency’s Draft Standard Audit Policy Agreement (“Draft Agreement”). IPAA believes that the Audit Policy is an important tool in furtherance of environmental compliance and appreciates EPA’s interest in expanding its use by proposing to adopt a more flexible approach to eligibility and administration.
