June 16, 2014 

### PIOGA 115 VIP Drive, Suite210 Wexford,PA 15090-7906

The Honorable Gina McCarthy, Administrator U.S. Environmental ProtectionAgency EPAWest (Air Docket), Room 3334 1301 ConstitutionAve.,NW Washington, DC 20004 Submitted viaemail to oilandgas.whitepapers@epa.gov


### RE: Comments ofthePennsylvania Independent Oil & Gas Association ("PIOGA") to WhitePapers on Methane and VOC Emissions in the Oil and Natural Gas Sector pertheClimateAction Plan Strategyto ReduceMethaneEmissions
DearAdministratorMcCarthy: 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 ofemissions in the oil and natural gas sector. While EPA has not opened a docket and the release ofthe 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 inputfrom thepeerreviewpanels and general public will serve as the basis for public policy decisions regardingpotential reductions in methane emissions from the oil and natural gas sector. As you are aware, the five White Papers coverthe following types ofsources or activities within the oil and natural gas sectors: (1) compressors; (2) emissions from completions and ongoing production ofhydraulically 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.

Page 1of2PIOGA 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 ofPennsylvania'scrude 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 ofthe Commonwealth ofPennsylvania

- 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 ofthe air emissions associated with large, unconventional operations. PIOGA therefore believes that the "one-size fits all" approach contemplated for the potential regulation ofmethane 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 ifthe same were setforth at lengthagain, the otherAssociations' commentsto 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 contactme orRoy Rakiewicz at (610) 933

-5246 x 127 ifyou 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

Page 2 of2 Subcommittee, Oil and Gas