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Comments opposing the gap for existing emission sources, and joint comments opposing the exclusion of coal bed methane wells

Cover letter for the comments:

November 30, 2011

Environmental Protection Agency Washington, DC

Regarding: Docket ID Number EPA–HQ–OAR–2010–0505 – Comments submitted on behalf of Earthworks, Powder River Basin Resource Council and San Juan Citizens Alliance

We appreciate the opportunity to provide these two sets of written comments to you. One set of comments, prepared on behalf of Earthworks, addresses the gap in the proposed rules for existing sources of emissions. The second addresses the issue of whether emissions from CBM wells should be exempt from portions of the rules. Powder River Basin Resource Council and San Juan Citizens Alliance have joined with Earthworks in submitting this set of comments.

Collectively, we have thousands of members throughout the Rocky Mountain states, in Texas and in the Marcellus shale region. Many of our members are impacted by the currently unregulated emissions from oil and gas operations throughout those states. So this proposed regulation providing a new source performance standard for Volatile Organic Compounds; a new source performance standard for sulfur dioxide; an air toxics standard for oil and natural gas production; and an air toxics standard for natural gas transmission and storage is of great importance to our members.

Overall, we strongly support the draft rule as a significant first step in addressing emissions from upstream oil and gas operations. Generally, we believe that the rule will lead to greater transparency from this powerful industry in the form of accounting for the numerous sources of emissions that are currently ‘invisible’ due to the lack of regulation. We also believe that the rule will provide health benefits to those who live close to the thousands of gas facilities covered by this rule. And we believe that the rule will provide an economic benefit to this industry, through the capture of additional ‘product’ that can be sold in the marketplace. We are confident that an industry which has figured out horizontal drilling techniques, and the thousands of versions of hydraulic fracturing chemical ‘cocktails’ which have unlocked access to shale gas, will also be able to find a way to comply with this rule while remaining highly profitable.

Consistent with the recommendations of the Department of Energy’s Shale Gas Subcommittee recommendations, we also believe that the final rule should be expanded to include the thousands of existing wells and facilities, which already constitute a significant source of emissions, and resulting impacts to people living, working or going to school nearby.

Respectfully submitted,