## Date: April 7, 201 6
Meetin g: Met hane R ule Rule(s) Discussed:
W ritten Mater ials& o:



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# +OVERVIEW OF COMMENTS ON EPA'S PROPOSED AIR RULES 

### (2015) 

### Anadarko Petroleum Co rporation- An Industry leader December 

### 1, 2015 Anadarko Petroleum Corporation is one of the nation 's leading producers of clean-burning natural gas
. We are amo ng the world's largest ind ependent o il and natural gas exploration and production compa n ies operating approximately 25,000 wells in the United States. Anada r ko's onshore U.S. operations are located in the Rocky Mountain areas, the southern U.S., the Appalachian basin and Alaska. We are proud that our company's voluntary actions and collaborative approach with regulators and other stakeholders are result ing in cleaner air, fewer emissions and more of our product reaching our customers. Our company has played a transformative role in how energy resources are bring produced, which includes implementing emission-reduction technologies and best practices across our operating areas. We also focus on improving the science around methane emissions through studies with respected academic institutions and the Environmental Defense Fund. We demonstrated our support for the collaborative, const r uctive and state-led approach that resulted in Colo rado's revisio n of Regulation No. 7 on air quality. These constructive and collaborative efforts are reducing emissions and ensuring natural gas remains abundant and affordable as it continues to be the most reliable and scalable option available for achieving U.S. carbon-reduction targets. We encourage the Environmental Protection Agency (EPA) to continue to enhance the opportunities to provide companies incentives for early action, including by providing states the maximum flexibility in developing their programs. Source Determination : Proposed Rule 

### Determinationfor Certain Emission Units in the Oil and Natural Gas Sector, 40 C.F.R. Parts 

### 49, 51 , 52, 70, 71 Federa l and state emission control requirements for upstream oil and natural gas facilities are based on the type of equipment installed. The type of equipment on-site will not change based on the aggregation of locations. The proposal will simply change the complexity of permitting with negligible air quality improvements. This proposed rule will overwhelm permitting agen cies with permit applications and permit modification applications; permits will not be issued in a predictable timeframe causing delays for oil and natural gas development and great regulatory uncertainty. Anadarko agrees clarification will help both the regulators and regulated community, but that clarification should comport w ith the CAA language and case law. Anadarko is proposing the following alternative language to provid e the balance: "Cont iguous or adjacent properties" mean surface areas with an affixed building, structure, faci li ty or installation includ i ng permanently graded or cleared areas for such building , structu re , facility or installation, that share an edge/boundary, physically touch, and are adjoining or physically abutting. As proposed, the rule suffers from a number of legal flaws that will subject the rule to legal challenge and possibly more uncertainty. We believe this is the not the objective of EPA, nor the desire of the regulated community

. EPA should ensure the rule is addressing the legal concerns raised in comments, and work directly with the oil and natural gas sector to develop the appropriate guidance. This rulemaking: (1) offers minimal to no environmental benefit; (2) fails to eva lu ate the economic impacts required under the Clean Air Act (CAA); and (3) significantly increases administrative burden, costs, delays and inefficiencies to permitting programs nationwide.New Source Perform ance Standard {NSPS) Subpart OOOOa: Propose d Rule Standards afPerformance for New Stationary Sources: Oil and Natural Gas Production and Natural Gas Trans mi ssion and Di stribution We share the concerns of our industry that EPA's one-size-fits-all proposed methane regulations would significantly and unnecessarily increase costs. Such an approach will also carry the unintended consequence of curbing further emission reductions by discouraging voluntary, collaborative and state-based sol utions that have proven successful in encouraging innovation and improving our indu st ry's environmenta l performance. We support EPA's stated objectives to achieve the most reductions with the least regulatory burden. However, the proposed rulemaking deviates from this stated goal on a number of levels. Among the most notable, is the proposal by EPA to impose a leak detection and repair (LDAR) program on states that already have legally and practicably enfo rceable programs
. The rule should provide states the ability to develop a state-specifi c LDAR program
. The federal rulemaking can provide general principles for a program, without prescriptive requirements dictating the components of a state program. The rule should further affirm that a state with an existing LDAR program that meets the general principles, also meets the requirements of the federal rule. Federal Implementation Pl an {FIP} for Managing Air Emission s from True Minor Sources Engaged in Oil and Natural Gas Production in Indian Country As written, this particular rule has limited uti l ity since it can only be utilized in attainment areas and for true minor sources. The FIP should be modified to:
• Include a plan for areas transitioning from attainment to nonattainment;

• Provide a streamlined mechanism for synthetic minors; and
• Allow for a pre-construction registration and post-production emission calculations. Natural Gas STAR M e than e Chall e nge This voluntary program comes on top of the ongoing aforementioned rule makings and other regulations for the oil and natural gas industry, which include: lowered Ozone National Ambient Air Quality Standard , expanded greenhouse gas (GHG) reporting rule, Bureau of Land Management fracking rule, GHG regulation of new and existing utilities, Refinery Sector Rule, Council on Environmental Quality guidance on address in g climate change under the National Environmental Policy Act, and Waters of the US. With all the other regulatory activities , at this time, it will be difficult for industry to find incentives or the resources to pursue voluntary measures as reflected in the Methane Challenge

. To date, EPA has not adequately created synergy between its voluntary program and numerous other regulatory initiatives. Program partici pation coul d be increased if EPA takes a more holistic view of the burdens it i s imposing on industry and develops a program that provides a business justification. We encourage EPA to collaborate with industry around voluntary programs that maximize methane reductions without the burden of formal regulatory initiatives that are limited in focus and effectiveness.

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