Aug 7, 2023 Comment Extension and Public Hearing Request for EPA Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems
Subject: Comment Deadline Extension Request for Docket Id. No. EPA-HQ-OAR-2023-0234, Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems, and a Request for a Public Hearing that includes a Presentation on the Proposed Changes
Dear Mr. Regan:
The Petroleum Alliance of Oklahoma, the Independent Petroleum Association of America and Western Energy Alliance (collectively referred to as the Trades) request the Environmental Protection Agency (EPA) extend the public comment period by an additional 60-days for Docket Id. No. EPA-HQ-OAR-2023-0234, Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems (Proposed Rule). In addition, we request EPA conduct a public hearing that includes a presentation on the proposed changes.
The Proposed Rule was published in the Federal Register on August 1, with a comment deadline of October 2. This Proposed Rule includes 160 pages of text along with 136 supporting documents that encompass hundreds if not thousands of pages of supporting material. The Trades do not think the 60-day comment period is adequate to fully review the Proposed Rule and supporting material and provide meaningful comments on such a short timeline.
EPA currently has three proposed Greenhouse Gas Reporting Rules (GHGRRs) that have not been finalized: EPA’s initial proposed GHGRR (87 Fed. Reg. 36920, June 21, 2022), the Supplemental Proposed Rule (88 Fed. Reg. 32852, May 22, 2022) and this Proposed Rule for Subpart W for the petroleum and natural gas systems. In addition, EPA’s proposed New Source Performance Standards for new and existing oil and gas sources (NSPS b/c), integral to the GHGRRs, are still not finalized, adding an additional level of complexity to the review process of the Proposed Rule. Taken together, these proposed rules are expansive and provide significant uncertainty as to how they collectively build upon and/or function together. The Trade’s members need the additional 60-day review time to carefully review the Proposed Rule in context with the other proposed rules to better understand the cumulative costs impacts and requirements in order to provide fully informed comments. …
