Jan 30, 2024 IPAA Request to EPA for Extension of Waste Emissions Charge Comment Period
Dear Mr. Ragnauth,
The Independent Petroleum Association of America (IPAA) respectfully requests a 30-day extension of the public comment period for the Environmental Protection Agency’s (EPA) Proposed Rule, “Waste Emissions Charge for Petroleum and Natural Gas Systems (“WEC Rule”) [89 FR 5318]. …
EPA has failed to adequately recognize and address the myriad crosscutting issues among the WEC Rule, EPA’s proposed Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas System (“Subpart W Rule”) [88 FR 50282], and EPA’s proposed New Source Performance Standards and Emission Guidelines for Crude Oil and Natural Gas Facilities: Climate Review (“Methane Rule”) [87 FR 74702]. EPA has also failed to recognize the risks to the workability and durability of these rules posed by an inadequately coordinated rulemaking process.
IPAA believes a 30-day extension of the WEC Rule comment period is both necessary and reasonable in order for IPAA staff and its members to fully analyze the proposed WEC Rule and its connections to the Subpart W Rule and Methane Rule, develop comments, and inform EPA’s final rule. Thank you for your prompt consideration of this request.
