IPANM (Feb. 14, 2023) – IPANM joined 20 other producer associations today in filing comprehensive comments that represent many concerns over EPA’s proposed Federal Methane Rule, Docket ID No. EPA-HQ-OAR-2021-0317. IPANM has participated in the “Producer Associations” consortium for the past few years, and many concerns voiced by IPANM were included in the final comment documents submitted today.
The comments include the following overview:
“The message the Producer Associations have consistently conveyed since 2011 is “one size does not fit all.” Generally speaking, EPA’s response has been to regulate exploration and production (“E&P”) emission sources to the extent that EPA believes it can “survive”/continue to exist – that is not the “best system of emission reduction” (“BSER”) as required by Section 111 of the Clean Air Act (“CAA”). [The Producer Associations] T comments are intended to identify the most detrimental and unsupported proposals by EPA and provide alternatives that
provide the equivalent or nearly the equivalent environmental benefits as substantially less cost and confusion to the Oil and Gas Industry, in particular the small business that are disproportionally impacted by these proposed regulations.”
To read the full text of the Producer Associations 48-page comments, please click below.
Feb. 14, 2023 Producer Associations Final Comments on Federal Methane Rule
