Comments of the Producer Associations on the November 15, 2021 Oil & Natural Gas NSPS Proposal

Dear Administrator Regan:

Please accept the comments of the following oil and natural gas associations and associations that support the industry on EPA’s proposal regarding New Source Performance Standards for the Oil and Natural Gas source sector:  Independent Petroleum Association of America (IPAA), Arkansas Independent Producers and Royalty Owners (AIPRO), Domestic Energy Producers Alliance (DEPA), Eastern Kansas Oil & Gas Association (EKOGA), Gas & Oil Association of West Virginia (GO-WV), Illinois Oil & Gas Association (IOGA), Independent Petroleum Association of New Mexico (IPANM), Indiana Oil and Gas Association (INOGA), International Association of Drilling Contractors (IADC), Kansas Independent Oil & Gas Association (KIOGA), Kentucky Oil & Gas Association (KOGA), Michigan Oil and Gas Association (MOGA), National Stripper Well Association (NSWA), North Dakota Petroleum Council (NDPC), Ohio Oil and Gas Association (OOGA), The Petroleum Alliance of Oklahoma (The Alliance), Petroleum Association of Wyoming (PAW), Pennsylvania Independent Oil & Gas Association (PIOGA), Texas Alliance of Energy Producers (Texas Alliance), Texas Independent Producers & Royalty Owners Association (TIPRO), and Western Energy Alliance (Alliance) – collectively, the Producer Associations.  The Producer Associations look forward to working with the EPA to improve the proposed regulatory actions.