June 16, 2014 

PIOGA 

115 VIP Drive, Suite 210 

Wexford, PA 15090-7906 

The Honorable Gina McCarthy, Administrator 

U.S. Environmental Protection Agency 

EPA West (Air Docket), Room 3334 

1301 Constitution Ave., NW 

Washington, DC 20004 

Submitted via email to oilandgas.whitepapers@epa.gov 

RE: Comments of the Pennsylvania Independent Oil & Gas Association ("PIOGA") 

to White Papers on Methane and VOC Emissions in the Oil and Natural Gas Sector 

per the Climate Action Plan Strategy to Reduce Methane Emissions 

Dear Administrator McCarthy: 

The Pennsylvania Independent Oil & Gas Association ("PIOGA") appreciates the 

opportunity to provide comments on the United States Environmental Protection Agency's 

("EPA") White Papers on Methane and VOC Emissions ("White Papers") which were released 

for external peer review on April 15, 2014. The White Papers focus on technical issues relating 

to potentially significant sources of emissions in the oil and natural gas sector. While EPA has 

not opened a docket and the release of the documents for "comment" does not constitute formal 

rulemaking pursuant to the Administrative Procedure Act, EPA requested input from the public, 

including "technical information and data," by June 16, 2014. According to EPA, the White 

Papers and input from the peer review panels and general public will serve as the basis for public 

policy decisions regarding potential reductions in methane emissions from the oil and natural gas 

sector. 

As you are aware, the five White Papers cover the following types of sources or activities 

within the oil and natural gas sectors: (1) compressors; (2) emissions from completions and 

ongoing production of hydraulically fractured oil wells; (3) leaks from natural gas production, 

processing, transmission, and storage; ( 4) liquids unloading; and (5) pneumatic devices. The 

White Papers are organized in generally the same fashion, with sections reviewing the available 

data on emissions from the particular subsector, assessing the existing technologies or methods 

to reduce emissions from that subsector. 

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PIOGA is the principal nonprofit trade association representing Pennsylvania's 

independent oil and natural gas producers, marketers, service companies and related businesses. 

PIOGA member companies drill and operate the majority of Pennsylvania's crude oil and natural 

gas wells, including those in the Marcellus Shale. Our members have, for decades, successfully 

provided heat to the homes, gas to the stovetops, and energy to the citizens of the 

Commonwealth to grow and prosper their communities; all the while protecting the natural 

environment and air resources of the Commonwealth of Pennsylvania - the state that we call 

home. 

Many of PIOGA's members are small family-owned businesses with ten or fewer 

employees. Their operations are conventional and the air emissions from their operations are a 

small fraction of the air emissions associated with large, unconventional operations. PIOGA 

therefore believes that the "one-size fits all" approach contemplated for the potential regulation 

of methane in EPA's White Papers would visit a disproportionate, severe economic burden on 

these businesses. 

Today, the Independent Petroleum Association of America ("IPAA'') and Western 

Energy Alliance (the "Alliance") (collectively sometimes the "Associations") are likewise 

submitting comments to the White Papers. The other Associations' comments are extensive 

running roughly 25 pages. PIOGA agrees with, endorses and incorporates by reference as if the 

same were set forth at length again, the other Associations' comments to the White Papers. 

We appreciate the opportunity to provide comments on the White Papers and would be 

happy to have further discussion with the agency regarding the issues raised herein. Please 

contact me or Roy Rakiewicz at (610) 933-5246 x 127 if you have any questions regarding these 

comments. 

cc: Roy Rakiewicz 

Louis D. D'Amico 

Kevin Moody 

Respectfully submitted, 

By ~A){ Ronald S. Cusano 

Chair, Air - Quality -

Pennsylvania Independent 

Association 

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Subcommittee, 

Oil and Gas