These comments are filed in response to supplemental comments filed on April 13, 2020, by the Environmental Defense Fund (EDF) for itself and several other professional environmental issues advocacy organizations (EDF 2020 Comments). The EDF 2020 Comments address issues that arise in both the EPA......
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Dear Administrator Wheeler: The following Supplemental Comments are submitted on the above-referenced proposed Reconsideration Rulemaking (“Reconsideration Rulemaking”) on behalf of the following national and state trade associations: the Independent Petroleum Association of America (“...
Groups Share Recommend Changes to EPA’s Latest Revision to Better Account for Smaller Operators, Existing State Efforts and Emerging Technology WASHINGTON, D.C. – The Independent Petroleum Association of America (IPAA), representing the independent producers that develop 90 percent of America’...
The Independent Producers have participated individually or through the Independent Producers in most, if not all, of the rulemakings and associated litigation since the Environmental Protection Agency (“EPA” or “Agency”) proposed to revise the New Source Performance Standard...
In proposing withdrawal of the Control Techniques Guidelines for the Oil and Natural Gas Industry (CTG), EPA states: “On June 5, 2017, the EPA granted reconsideration in regard to additional provisions of the 2016 NSPS1. Pursuant to those actions, the EPA is currently looking broadly at the....
To Whom it May Concern: Western Energy Alliance (the Alliance) and the Independent Petroleum Association of America (IPAA) appreciate the opportunity to provide comments on the Bureau of Land Management’s (BLM) proposed revisions of certain provisions of the Methane and Waste Prevention rule, ...
