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Susan Bodine, Director
Office of Enforcement and Compliance Administration
Environmental Protection Agency

Dear Ms. Bodine,

Thank you for the opportunity to provide comments on the Environmental Protection Agency’s (EPA) proposed Oil and Natural Gas Exploration and Production Facilities New Owner Audit Program Agreement (Agreement). Please accept these comments on behalf of Earthworks, a nonprofit organization dedicated to protecting communities and the environment from the impacts of energy development while seeking sustainable solutions.

At the outset, voluntary programs are neither a substitute for mandatory compliance nor a mechanism for enforcement. EPA cannot meet its objectives of efficient compliance, easing regulatory burdens, cleaner air, and better health outcomes while shifting away from holding polluters accountable. This Agreement grants absolution for bad behavior in exchange for a new purchaser’s promise to improve.