Small Entity Representatives (SERs) Comments to Oil and Natural Gas NSPS to SBAR Panel

The following comments are submitted on behalf of the Gas and Oil Association of WV, Inc. (GOWV), the Independent Petroleum Association of America (IPAA) and Texas Independent Producers and Royalty Owners Association (TIPRO). Representatives of GO-WV, IPAA and TIPRO served as Small Entity Representatives (SERs) in the Small Business Advocacy Review Panel Process (SBAR Process) participating in the Pre-Panel Outreach Meeting on June 29, 2021; Panel Outreach Meeting on July 29, 2021 (SBAR Panel), and submitting certain comments after the June meeting. These comments are in response to information provided during both meetings. GO-WV, IPAA, and TIPRO appreciate the opportunity to serve as SERs, hopefully reducing the economic impact of the revisions to Subpart OOOO and/or Subpart OOOOa. A significant number or GO-WV, IPAA and TIPRO members not only qualify as “small entities” under the Regulatory Flexibility Act, but would also be characterized as “mom and pop” or family businesses. It is these smaller businesses that stand to lose the most by the regulations to be proposed at the end of September. …

Summary of Key Points:

• EPA continues to lack emissions data on low production wells to support regulatory decisions – but more data is close at hand.

• Exploring subcategorization of sources is warranted, if not obligated, and perhaps represents the most appropriate means to protect the environment while permitting and supporting small business which support rural communities and our country’s energy independence.

• Don’t “fix” what is not broken/don’t let “perfection” be the enemy of the good: EPA and the oil/gas industry have worked together for at least a decade on New Source Performance Standards (NSPS) focused on volatile organic compounds (VOCs) and/or methane emissions from the industry and progress has been made.