Feb 27, 2023 Producers Associations Comments Re: Adoption and Submittal of State Plans for Designated Faculties: Implementing Regulations Under Clean Air Act Section 111(d) Docket No. EPA-HQ-OAR-2021-0527
These comments are submitted to address proposed changes to the adoption and submittal of state plans implementing regulations under Clean Air Act (“CAA”) Section 111(d), 42 U.S. Code § 7411. The proposed changes would revise 40 CFR Part 60, Subpart Ba (“Subpart Ba”). The generic modifications to Subpart Ba are integrally related to the Environmental Protection Agency’s (“EPA”) proposed Subpart OOOOc which would create Emissions Guidelines (“EG”) for the oil and natural gas production industry. While the Subpart OOOOc proposal contains specific provisions regarding the application of Section 111(d), these generic changes to Subpart Ba would apply where Subpart OOOOc does not provide specific overrides. Moreover, the Producer Associations believe the concepts included in both proposals create broader issues that need to be addressed.
