Filed on regulations.gov — full text not in the inline record.
Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Reconsideration
Activity
Environmental Defense Fund filed 11 comments on this docket between Nov 27, 2018 and Jul 31, 2020. 58 other organizations filed here. The comment window closed 2780d ago.
What Environmental Defense Fund filed (11)
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We submit these comments on behalf of Environmental Defense Fund, Chesapeake Bay Foundation, Clean Air Council, Clean Air Task Force, Center for Biological Diversity, Earthjustice, Earthworks, Environmental Integrity Project, Environmental Law & Policy Center, National Parks Conservation Association, Natural Resources Defense Council, and Sierra Club (together, Environmental Commenters). There is an urgent need to reduce emissions of methane and other harmful pollutants from the U.S. oil and natural gas sector. Accordingly, Environmental Commenters strongly oppose EPAs Proposal to dramatically weaken vital and commonsense protections that the agency adopted over two years ago and that have been effective in delivering benefits for Americans across the country. EPA should withdraw this misguided proposal, to the extent it amends the 2016 standards EPA should strengthen them, and EPA should move forward expeditiously, consistent with EPAs duty under the Clean Air Act, to adopt standards reducing this harmful pollution from already-existing sources in the oil and natural gas sector.
Please accept these comments on the flawed monetization of forgone benefits, submitted jointly by Environmental Defense Fund, Institute for Policy Integrity at New York University School of Law, Sierra Club, Union of Concerned Scientists, and Western Environmental Law Center. We also attach some supporting sources. Other supporting sources are subject to copyright and so are not attached here, but their citations are provided in our comments, and EPA has access to the materials. Our organizations may separately submit other comments regarding other aspects of this notice. Sincerely, Jason Schwartz, Legal Director, Institute for Policy Integrity
On behalf of Environmental Defense Fund, we submit the attached materials into the docket for EPA's Oil and Natural Gas Emission Standard for New, Reconstructed, and Modified Sources Reconsideration. These materials include comments submitted on December 7, 2017 regarding Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources: Stay of Certain Requirements; and supplementary materials for Fann et al.
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To Whom It May Concern: Attached, please find the signatures of 73,739 EDF supporters from across the country who have commented in opposition to EPA's Proposed Rule: Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Reconsideration. The comment they each submitted reads: "I am writing today out of grave concern for your new proposal to gut America's crucial limits on methane pollution from the oil & gas industry. Allowing companies to put off basic inspection and repair requirements rewards the worst-run oil & gas companies in the country while threatening Americans' health and safety. "A recent study in Science magazine found methane emissions from the U.S. oil and gas industry are 60 percent higher than EPA reports -- which means we're wasting enough natural gas to power 10 million American homes every year. With the safeguards in question currently preventing 100,000 tons of methane pollution and 30,000 tons of smog-forming chemicals annually, we need them more than ever. "It is imperative that the EPA follow facts and common sense in order to protect the American public -- not industry's lowest performers. Please walk back this attack immediately." Please feel free to contact me directly if you have any questions or concerns about this submission. Thank you for your consideration, Heather Shelby Action Network Manager Environmental Defense Fund hshelby@edf.org (202) 572 3242
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The Environmental Defense Fund, Center for Biological Diversity, Clean Air Task Force, Earthjustice, Environmental Integrity Project, Environmental Law & Policy Center, National Parks Conservation Association, Natural Resources Defense Council, and Sierra Club respectfully request an extension of the public comment period for the Environmental Protection Agencys rulemaking regarding Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Reconsideration, 83 Fed. Reg. 52,056 (Oct. 15, 2018). Please see attached request.
Abstract
On June 3, 2016, the Environmental Protection Agency (EPA) finalized Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources (40 CFR Part 60 Subpart OOOOa). EPA received five petitions for reconsideration on the 2016 OOOOa rule. By a letter dated April 18, 2017, the EPA announced the convening of a proceeding for reconsideration of certain provisions in the 2016 OOOOa rule. On June 5, 2017, the EPA granted reconsideration of additional requirements in that rule.
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See everyone who commented →- Environmental Defense FundTHIS ORG11 filings · confidence 97%
- Independent Petroleum Association of Americatrade assoc.4 filings · confidence 85%
- American Petroleum Institutetrade assoc.3 filings · confidence 97%
- National Tribal Air Associationtrade assoc.2 filings · confidence 85%
- Panhandle Producers and Royalty Owners Associationtrade assoc.2 filings · confidence 85%
- Texas Independent Producers & Royalty Owners Associationtrade assoc.2 filings · confidence 85%
- a GE Companyunverified attribution1 filing · confidence 70%
- Alaska Oil and Gas Associationtrade assoc.1 filing · confidence 85%
- American Chemical Societytrade assoc.1 filing · confidence 85%
- Association to Preserve Cape Codtrade assoc.1 filing · confidence 85%
- BlueGreen Alliancetrade assoc.1 filing · confidence 85%
- BP America Inc.unverified attribution1 filing · confidence 70%
- Chevron U.S.A. Inc.unverified attribution1 filing · confidence 70%
- Colorado Oil & Gas Associationtrade assoc.1 filing · confidence 85%
- Committee on Natural Resourcestrade assoc.1 filing · confidence 85%
- Conservation Committeetrade assoc.1 filing · confidence 85%
- Conservation Committee of The Garden Club of Americatrade assoc.1 filing · confidence 85%
- Countrymark Corporationunverified attribution1 filing · confidence 70%
- CSODA Operating Company LLCunverified attribution1 filing · confidence 70%
- Domestic Energy Producers Alliancetrade assoc.1 filing · confidence 85%
- Encana Oil & Gas (USA) Inc.unverified attribution1 filing · confidence 70%
- Extractive Industriesunverified attribution1 filing · confidence 70%
- GPA Midstream Associationtrade assoc.1 filing · confidence 97%
- Independent Oil & Gas Association of West Virginia.trade assoc.1 filing · confidence 85%
- Inland Ocean Coalitiontrade assoc.1 filing · confidence 85%
- Interstate Natural Gas Association of Americatrade assoc.1 filing · confidence 97%
- Kansas Independent Oil & Gas Associationtrade assoc.1 filing · confidence 85%
- Kentucky Oil and Gas Associationtrade assoc.1 filing · confidence 85%
- LLC dba Digital Abstract and Titleunverified attribution1 filing · confidence 70%
- Mass Comment Campaign sponsored by BlueGreen Alliance (web)trade assoc.1 filing · confidence 85%
- Mass comment campaign sponsored by National Wildlife Federation Action Fund (web)trade assoc.1 filing · confidence 85%
- Mass Comment Campaign sponsored by Northern Plains Resource Council (email)trade assoc.1 filing · confidence 85%
- Mass Comment Campaign sponsored by Ohio Environmental Council Action Fundtrade assoc.1 filing · confidence 85%
- Mass Comment Campaign sponsored by Union of Concerned Scientists (web)unverified attribution1 filing · confidence 70%
- Michigan Oil and Gas Associationtrade assoc.1 filing · confidence 85%
- National Society of Professional Engineerstrade assoc.1 filing · confidence 85%
- National Wildlife Federationtrade assoc.1 filing · confidence 85%
- Natural Resources Defense Council (NRDC)trade assoc.1 filing · confidence 97%
- New Mexico Oil and Gas Associationtrade assoc.1 filing · confidence 85%
- New York University School of Lawunverified attribution1 filing · confidence 70%
- Ohio Oil and Gas Associationtrade assoc.1 filing · confidence 85%
- Pennsylvania Grade Crude Oil Coalitiontrade assoc.1 filing · confidence 85%
- Pennsylvania Independent Petroleum Producers Associationtrade assoc.1 filing · confidence 85%
- Permian Basin Petroleum Associationtrade assoc.1 filing · confidence 85%
- Petroleum Association of Wyomingtrade assoc.1 filing · confidence 85%
- PLLC on behalf of the Independent Petroleum Association of Americatrade assoc.1 filing · confidence 85%
- President & Executive Director Pennsylvania Independent Oil & Gas Associationtrade assoc.1 filing · confidence 85%
- Red Willow Production Companyunverified attribution1 filing · confidence 70%
- Texas Oil and Gas Associationtrade assoc.1 filing · confidence 85%
- Texas Pipeline Associationtrade assoc.1 filing · confidence 97%
- Texas Royalty Council and American Royalty Counciltrade assoc.1 filing · confidence 85%
- Union of Concerned Scientistsunverified attribution1 filing · confidence 70%
- Ute Tribal Business Committee on behalf of the Ute Indian Tribe of the Uintah & Ouray Reservationtrade assoc.1 filing · confidence 85%
- Vermont Gas Systemsunverified attribution1 filing · confidence 70%
- Vice President of Regulatory Affairs Ohio Oil and Gas Associationtrade assoc.1 filing · confidence 85%
- West Virginia Oil and Natural Gas Associationtrade assoc.1 filing · confidence 85%
- Western Energy Alliancetrade assoc.1 filing · confidence 85%
- Western Governors Associationtrade assoc.1 filing · confidence 85%
- WS Badger Companyunverified attribution1 filing · confidence 70%