Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources: Stay of Certain Requirements

Attached please find sources referenced in the joint comments of Clean Air Council, Clean Air Task Force, Center for Biological Diversity, Earthjustice, Earthworks, Environmental Defense Fund, Environmental Integrity Project, Environmental Law and Policy Center, Natural Resources Defense Council, Sierra Club, and National Parks Conservation Association on the notice of data availability (NODA) for the proposed rule, Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources: Three Month Stay of Certain Requirements, 82 Fed. Reg. 51794 (November 8, 2017). This is the first of two submissions for sources referenced in these comments.

Attached please find the joint comments of Clean Air Council, Clean Air Task Force, Center for Biological Diversity, Earthjustice, Earthworks, Environmental Defense Fund, Environmental Integrity Project, Environmental Law and Policy Center, Natural Resources Defense Council, Sierra Club, and National Parks Conservation Association on the notice of data availability (NODA) for the proposed rule, Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources: Three Month Stay of Certain Requirements, 82 Fed. Reg. 51794 (November 8, 2017). This comment submission includes four supplemental comments: 1.Renee McVay and Hillary Hull, Assessment of State-Level Fugitive Emissions Programs in Comparison to EPA NSPS (December 8, 2017) 2.William Allison, Colorado's Implementation of Requirements for Leak Detection and Repair and Closed Vent Systems (Dec. 8, 2017) 3.MJ Bradley - Memorandum, Estimate of Professional Engineers in O&G Industry (Dec. 6, 2017) 4.MJ Bradley - Memorandum, LDAR Workforce Analysis (Dec. 6, 2017) Sources referenced in these comments are uploaded to this docket separately. These comments are also submitted to the docket for the NODA for the proposed rule, Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources: Stay of Certain Requirements, 82 Fed. Reg. 51788 (November 8, 2017) (EPA-HQ-OAR-2010-0505).

On behalf of the Environmental Defense Fund, Center for Biological Diversity, Clean Air Task Force, Earthjustice, Environmental Integrity Project, Environmental Law & Policy Center, Natural Resources Defense Council, and Sierra Club, attached please find a letter respectfully requesting that EPA hold a public hearing on EPA's November 8, 2017, notices of data availability on Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources: Stay of Certain Requirements, 82 Fed. Reg. 51,788 (Nov. 8, 2017), and Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources: Three Month Stay of Certain Requirements, 81 Fed. Reg. 35,824 (Nov. 8, 2017).

Attached please find a letter from Environmental Defense Fund, Center for Biological Diversity, Clean Air Council, Clean Air Task Force, Earthjustice, Environmental Integrity Project, Environmental Law & Policy Center, National Parks Conservation Association, Natural Resources Defense Council, and Sierra Club, respectfully requesting that EPA make public all annual compliance reports submitted by operators of oil and natural gas facilities to EPA as required by 40 C.F.R. Part 60 Subpart OOOOa. We also respectfully request that you extend the period for public comment on EPA's November 8, 2017, notices of data availability on Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources: Stay of Certain Requirements, 82 Fed. Reg. 51,788 (Nov. 8, 2017), and Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources: Three Month Stay of Certain Requirements, 81 Fed. Reg. 35,824, (collectively, "the NODAs") for at least 90 days after those reports are made available.

Filed on regulations.gov — full text not in the inline record.

Filed on regulations.gov — full text not in the inline record.