Memorandum 

Subject: 

From: 

To: 

July 29 20-1.4 

July 17, 2014 Meeting Between the Western Energy Alliance and its 

Members and the U.S. Environmental Protection Agency (EPA) 

Outreach 

Chris Stoneman, 

and Information 

Policy Advisor 

Division, 

~ ~ 

Office of Air Quality Planning and Standards (OAQPS) 

Docket- EPA-HQ-OAR-2011-0151 

This memorandum to docket provides a brief summary of the main discussion points 

made at the subject meeting during the comment period for the Advance Notice of 

Proposed Rulemaking (ANPR): "Managing Emissions from Oil and Natural Gas 

Production in Indian Country." (79 Federal Register 32502, June 5, 2104) 

Meeting details: 

When: July 17, 2014; 3:00-4:00 p.m. ET 

Where: EPA Offices, RTP, NC 

Participants: Chris Stoneman, EPA, OAQPS 

Cindy Beeler, EPA, Region 8 

Laura McKelvey, EPA, OAQPS 

Deirdre Rothery, EPA, Region 8 

Bob King, WPX Energy 

Bret Gallo, Bison Engineering 

Chad Powell, L T Environmental 

Craig Allison, XTO 

Curtis Rice, EOG 

Daubs Thompson, Greenberg Traurig 

Dave Scott, Beatty & Wozniak 

Doug Renderer, Newfield Exploration 

Drew Hall, Halcon 

Emily DeGrasse, Crescent Point Energy 

Greg Schrab, SM Energy 

Jagadeesan Sethuraman, Whiting Petroleum 

Jennifer McQueen, L T Environmental 

Jennifer Najjir, Davis Graham & Stubbs 

Jessica Berg, Gasco Energy 

Jill Cooper, Anadarko 

Julia Jones, Anadarko 

Karen Pratt, XTO 

Katherine Doolittle, Anadarko 

Kristin Dickinson, Enerplus 

'· 
Nica Hoshijo, WPX 

Ray Gorka, Slawson 

Rick Matar, WPX 

Rob Thompson, Greenberg Traurig 

Ron LePlatt, QEP Resources 

Rusty Frishmuth, Bill Barrett 

Scott Mason, Enerplus 

Shane Schulz, QEP Resources 

Steve VanOotegham, Halcon Resources 

Todd Rudolph, Ultra Petroleum 

Tom Monohan, XTO Energy 

Tristan Walker, Halcon 

Ursula Rick, Western Energy Alliance (WEA) 

The EPA met with WEA at the energy organization's request. During the meeting, EPA 

provided an overview of several key aspects of the minor source general permit program 

for Indian country and the· recently-issued ANPR for New Source review (NSR) minor 

source oil and natural gas activity in Indian country. During the course of the meeting the 

Western Energy Alliance and its members raised several questions that were discussed 

(see attached agenda): 

• Whether EPA's recently-proposed general permit for engines applies to the oil 

and gas sector; 

• Need for a post-construction permitting approach that would have controls in 

place at start-up when production rates and emissions are the highest but would 

allow industry to understand the annual emissions at a given well before 

determining the type of permit required; 

• The way states permit minor sources in the oil and natural gas sector; 

• Different approaches for permitting minor oil and natural gas sources in Indian 

count!)'; 

• Higher co~ts associated with retrofitting older wells with control equipment; 

• The use of synthetic minor sources in the oil and natural gas sector; 

• Improved coordination between the Bureau of Indian Affairs, the Bureau of Land 

Management and the EPA in the approval of oil and gas activities in Indian 

country and on public lands; and 

• Role of the Bureau of Indian Affairs and the Bureau of Land Management in the 

approval of oil and gas activities in Indian country and on public lands; and 

• How to structure a general permit/permit by rule that must cover several different, 

diverse parts of Indian country, and different basin characteristics with oil and 

natural gas activity. 

The EPA answered basic questions about the content of the ANPR and offered to be 

available for further discussions and/or exchanges of technical information. 

This memorandum will be filed in the docket for the proposed rule and will be available 

for public review.