Karin Foster, Esq . Executive Director IPANM 5805 Mariola Place, NE Albuquerque, NM 87111 Fosterassociates2005@Yahoo.com

June	13,	2014 US	EPA	Office	of	Air	Quality Planning	and	Standards	(OAQPS) Raleigh,	NC By	email: oilandgas.whitepapers@epa.gov Re:	 IPANM	 comments	 to	 OAQPS	 Oil	 and	 Natural	 Gas	 Sector liquids	 unloading Whitepaper Dear	Sir	or	Madam;
The	 Independent	Petroleum	Association	of	New	Mexico	 (‘IPANM’)	appreciates	 this opportunity	to	comm ent	to	the EPA	Office	of	Air	Quality	Planning	&	Standards	(hereinafter ‘EPA’)	whitepaper	on	Oil	and	Gas	Sector liquids	unloading of	April	2014

. Preliminary	matters: Without	adequate	research	and a n expert understanding	of	 the	issues,	it	would	be unethi cal	 for	 th e	 EPA to	 move	 forward	 with	 promulgating methane	 reductions policy	 or rules	 at this	 time. The whitepapers	 and	 studies	 cited	 therein	 do	 not	 appreciate	 that	 the
issues	 around	 methane	 reductions are complex	 and	 very	 dynamic. In	 fact, since	 the
intr oduction	 of	 the	 First	 Assessment	 Report	 (FAR)	 of	 the	 Intergovernmental	 Panel	 of Climate	 Change	 (IPCC	 1990),	 there	 has	 been vigorous discussion	 about whether global warming	potential	(GWP)	to compar e different	gases	on	a	CO2	equivalent	scale should	beIPANM	Comments: Liquids	Unloading	Processes Whitepaper June 13,	2014 Page 2 of 11

------------------------------------------------------------------ the	a ccepted	methodology	to	understand	the	true	impacts	of	methane

. 1 2 As	recently	as	last month,	MIT	 researchers	 published a	letter,	 titled,	 “ Climate	impacts	of	energy	 technologies depend	on	emissions	timing” in Nature	Climate	Change stating	that	the	sta tic	n ature	of	GWP to	compare	ga ses	with	differing	radiative	efficiencies	and	atmospheric	lifetimes	has	led	to ‘major	 shortcomings’	 in	 understanding	 energy	 technology	 valuations 3

. However,	 i n	 the
urgency to	complete	methane	reductions	regulations	by	 the	end	of	2 016,	 the	Whitehouse has	directed	the	EPA	draft	whitepapers	and convene	peer	review	panels to	give	the	agency a	‘robust	understanding’	of	the	issues.		IPANM	would	contend	that	these	whitepapers	were obviously	rushed,	had	a	limited	and	biased	selection	of	st udies	and	we	question	the	efficacy of	the	peer	review	process.		We	hope	that	the	agency	would	proceed	with	this	process in	a manner	 that allows	 for true	 stakeholder	 involvement	 and	 opportunity	 for	 comment as required	in	the federal Administrative	Procedure s	Act. Finally,	we	would	urge	the	agency	to use	the	resources	and	expertise	available	at	the	New	Mexico	Petroleum	Recovery	Research Center	 to	learn	about	 the	unique	characteristics	of	oil	and	gas	operations	in	 the	San	 Juan and	 Permian	 basins. Within	 the	 PR RC	 is	 the Research	 Partnership	 to	 Secure	 Energy	 for America	 (RPSEA),	 Small	 Producer	 Program which	is	 a public/private	 partnership	 funded by	 the	U.S.	DOE	 through	 the	National	Energy	Technology	Laboratory.	The	Small	Producer Program	aims	 to	develop	and	apply technology	 that	enhances	small	producer	production, and	 thereby	 contributes	 to	 the	 nation’s	 energy	 supply.	 The	 PRRC/New	Mexico	 Tech	 was

1 Shine,K. “ The global warming potential

– the need for an interdisciplinary retrial” Climactic Change Journal, Oct. 2009, vol. 96, issue 4, p. 467

- 472. 2 Even as one of the lead authors of one of the chapters of the first IPCC report, Dr. Shine questions whether using the ‘simple approach’ of global warming potential metrics improperly influenced a ‘major piece of environmental legislation’ (Kyoto Protocol) that could impact ‘big investment and policy. ’ 3 Edwards, M. & Trancik, J., “ Climat e Change of energy technologies depend on emissions timing” , Nature Clim. Change Letter, May 2014,IPANM	Comments: Liquids	Unloading	Processes Whitepaper June 13,	2014 Page 3 of 11

------------------------------------------------------------------ chosen	 to	 lea d	 the	 SP	 program	 because	 of	 their track	 record	 of	 research	 and	 actions	 on behalf	of	small	oil	and	gas	prod ucers,	 for	whose	benefit	our	organization	was	established. IPANM	would	also	be	happy	to	provide	additional	input	to	the	EPA	in	the	development	of policy,	rules	and	regulation	on	methane	reduction	strategies. Who	is	IPANM: The	Independent	Petroleum	Asso ciation	of	New	Mexico,	IPANM,	represents	several hundred	independent	oil	and	gas	producers	who	live,	work	and	employ	New	Mexicans.		We are	small,	with,	on	average,	25	employees	who	often	wear	multiple	proverbial	hats,	but	we provide	enough	revenue	to	the	S tate	of	New	Mexico	to	support	31%	of	the	General	Fund 4

. We strive	to	be	stewards	of	the	land	in	a	state	where	nearly	41.8%	of	the	land	is	federally owned.		The	Bureau	of	Land	Management	New	Mexico	office	manages	one	of	the	largest	oil and	 gas	 programs	 in the	 agency	 controlling	 13.4	 million	 acres	 of	 public	 lands	 and	 26 million	 subsurface	 acres	 of	 federal	 oil,	 natural	 gas,	 and	 minerals.	 	 There	 are	 currently 30,561	active	wells	on	 federal	lands 5 ranking	New	Mexico	sixth	in	crude	oil	production	in the	nation	i n	2013 6 .	New	Mexico’s	marketed	production	of	natural	gas	accounted	for	4.8% of	U.S.	marketed	 natural	 gas	 production	in	 2012,	 despite	 a	 decline	in	 production	 of	 20% between	 2007	 and	 2012 7

. According	 to	 the	 Office	 of	 Natural	 Resources	 Revenue,	 in	 FY
2013	 th e	 Federal	 Government	 disbursed	 $478,732,193.90	 in	 revenues	 to	 New	 Mexico 8 , which	is	only	48%	of	the	total	royalty	revenues	collected	for	oil	and	gas	operations	on	NM federal	lands.

4 “Fiscal Impacts of Oil and Natural Gas Production in New Mexico: Preliminary report”, New Mexico Tax Research Institute, Jan 2014. 5 http://www.emnrd.stat e.nm.us/OCD/documents/OCD%20Well%20Statistics03272014.pdf 6 http://www.eia.gov/state/?sid=NM 7 Id. 8 http://statistics.onrr.gov/ReportTool.aspxIPANM	Comments: Liquids	Unloading	Processes Whitepaper June 13,	2014 Page 4 of 11

------------------------------------------------------------------ The	 process	 by	which	 these	whitepapers	were	 developed	was	 flawed	 and	 requi res	more study	and	expert	understanding	of	the	issues. Regulation	in	the	air	quality	arena	is	not	new,	however,	IPANM	would	contend	that the	 process	 by	 which	 the	 Whitehouse,	 through	 the	 EPA	 and	 the	 BLM , is	 seeking	 to implement new	 or	 substantially	 expan ded methane	 reduction	 strategies,	 is	 not	 tenable 9

. Note	 that	 IPANM	 does	 not	 contest	 the	 authority	 of	 the	 EPA	 to	 regulate	 Greenhouse	 Gas
emissions 10 ,	of	which	methane	is	a part	of	those	emissions 11 .		T he	authority	under	the	Clean Air	 Act	 and	 a	 growing	 body	 of case	 law,	 grants	 the	 complex	 balancing	 of	 “national	 and international	 policy	 against	 environmental	 benefit,	 our	 nation’s	 energy	 needs	 and	 the possibility	 of	 economic	 disruption”	 solely	 on	 the	 Environmental	 Protection	 Agency. See , American	Electric	Power	v .	Connecticut ,	131	S.Ct.	2527,	564	U.S.	 ____	,slip	op.	10

- 174	at	13 (2011).		Indeed,	through	out	the American	Electric decision,	the	US	Supreme	Court	justices refer	 to	 the	 EPA	 as	 the	 “experts” 12 in	 greenhouse	 gas	 and	 air	 quality	 matters. In	 the
Administrat ion’s	“2014	Climate	Action	Plan:	Strategy	 to	reduce	methane	emissions 13 ”, the
P resident	 orders	 the	BLM,	 the	EPA,	USDA,	DOE	and	even	international	agencies	 to	 target key	 sources	 including	 landfills,	 coalmines,	 agriculture	 and	 the	 oil	 and	 gas	 sector and to

9 IPANM does contend that the statutory jurisdiction to regulate methane reductions lies exclusively with the E PA and not the BLM which is attempting to regulate methane emissions under the guise of a prevention of waste legal theory. 10 In Massachusetts v. EPA , 549 U. S. 497 (2007), the US Supreme Court held that the Clean Air Act, 42 U. S. C. §7401 et seq., autho rizes federal regulation of emissions of carbon dioxide and other greenhouse gases, including methane. 11 IPANM does, however, contest the science behind the policy for reducing human caused methane sources. Several of our members pointed out in response to this exercise that the science of global warming and impacts of human activities have not been settled yet. I n 2012, CH4 accounted for about 9% of all U.S. greenhouse gas emissions from human activities. But water vapor in the atmosphere is responsible for 95 percent ofthe greenhouse effect and CO2 is responsible for 3.6 percent. A study from MIT reported on 5/30/07 said that 97% of all greenhouse gases are naturally occurring, and the remaining 3% are caused by man. So methane is only 3% of the 9%. Ins ignificant

. 12 American Electric Power v. Connecticut , 563 US _____, slip op. at p. 3, 16,17,18 13 March 2014 Climate Change Strategy: Reduction of Methane Emissions, found at http://www.whitehouse.gov/sites/default/files/strategy_to_reduce_methane_emission s_2014

- 03

- 28_final.pdf ,IPANM	Comments: Liquids	Unloading	Processes Whitepaper June 13,	2014 Page 5 of 11

------------------------------------------------------------------ pr omulgate	rules	to	reduce	methane	emissions.		The	White	House specifically	directs 14 the BLM	to	propose	updated	standards	to	reduce	venting	and	flaring 15
, and mandated	the	EPA to	draft	white	papers	focusing	on	technical	issues relating	to	methane	emissions	fr om “oil and	 co

- producing	wells,	liquids	 unloading,	leaks,	 pneumatic	 devices	and	 compressors” to “solicit	 input	 from	 independent	 experts 16 ” (hereinafter	 referred	 to	 as	 the	 EPA	 methane papers) .	 	 The	 EPA	 wa s	 further	 order e d to	 use	 these	 documents	 to	 “solidify its understanding	of	these	potentially	significant	sources	of	methane.” The EPA	methane papers	came	out	 for	peer	review	and	comment	one	month	after the	release	of	the	Whitehouse	report with	only 60	days 17 to	comment on	nearly	300	pages of	technical	data

. The Whitehouse report also	directed	the	agency	to	convene peer	review panels , which	was	done, but	those	panels	only	consist	of 5	persons	per	panel, and not one single	 small	 independent was included	 o n	 any	 panel

. It	 is	 interesting	 to	 note	 that	 the
Environ mental	 Defense	 Fund,	 however,	 was	included	 on	 every	 panel th ereby	 giving	 that group	a	significant	voice	in	this	process

. From a	 detailed	 review	 of	 the EPA	methane	 papers , it	is	 obvious that	 the	 authors

w ere	 clearly	 limited,	 probably	 due	 to	 time	 constrai nts,	 to	 a	 small subset of	 studies	 that were	 often	 out	 of	 date ,	 had	 poor	 sampling	 criteria, had wildly	 inaccurate	 extrapolation factors or	 cite	 to	 each	 other	 as	 ‘science’

. Of	 the	 few	 studies	 the	 EPA	 relied	 upon,	 every

14 President’s Methane Reduction Strategy, page 2, 9

. 15 The BLM Venting and Flaring public outreach sessions were conducted in North Dakota, New Mexico and Washington DC. IPANM has submitted substantive comments to the BLM on their May 2014 Venting & Flaring proposal and would urge both the BLM and this agency to include IPANM, PRRC or RPSEA (see discussion above) in future stakeholder discussions. 16 Id. at 8 par. 2. 17 60 days to read and digest nearly 300 pages of technical infor mation was very difficult. To require industry to commission, prepare and present data to augment the very weak studies relied upon by the EPA was impossible. In addition, the timeframe set did not avail IPANM the ability to structure studies with the New Mexico Petroleum Recovery Research Center or RPSEA who are the entities often commissioned for such work.IPANM	Comments: Liquids	Unloading	Processes Whitepaper June 13,	2014 Page 6 of 11

------------------------------------------------------------------ whitepaper referenced a	 study	 commissio ned	 by	 the	 Env ironmental	 Defense	 Fund that reviewed	only	22	sources	of	emissions

. IPANM	strongly	contests	the	use	of	this	paper	as the	 assumptions	 used	 are	 wildly	 inaccurate.	 	 First,	 t he	 average	 $4mcf	 value	 is	 high, particularly	for	smaller	operators	who received	much	less	on	average	during	most	of	2012 and	 2013 18 .	 	 Second,	 the	 base	 assumption	 that	 the	 cost	 of	 flaring	 is	 only	 $ 3523	 per	 well ignores	the	true	costs	which,	by	IPANM	member	review, were well in	excess	of	$10,000	per
well because	 of	 the equipmen t	 rental,	 mileage,	 time and	 personnel	 time	 to	 operate	 the equipment.			As	noted	earlier	in	this	comment,	the	small	producer	has	significantly	different economics	 than	 major	 companies	 who	 employ	 personnel	 versus	 hiring	 consultants	 or
contractors	at	market	r ate	to	conduct	a	test	or an	emergency	procedure	such	as	a	flare	or venting	 during	 liquids	 offloading.	 	 The	 misuse	 of	 the	 cost	 figures	 which ICF	 then extrapolated	 to	 estimate	 savings	 on	 a	 nationwide	 basis	 renders	 the	 EDF	 study	 close	 to meaningless	 as	 a	 foun dation	 for	 a	 Whitehouse	 methane	 reduction	 strategy. Clearly, the
manner	 in	 which	 the	 EPA researched	 the	 is sues	 raised	 in	 the	 whitepapers	 wa s	 nothing more	 than	 a	 ‘data	 dump’	 that	 c ould not	 be	 considered an	 adequate	 learning	 process	 to establish	 expertise	 o n	 these	 very	 complex	 matters

. IPANM	 contends	 that	 based	 on	 the inadequate	 information	 reviewed , that	 the	 EPA	 does	 not	 have	 any	 sort	 of	 a	 ‘robust understanding 19 ’ of	 these	 sources	 of	 methane	 thus,	 moving	 forward	 with	 policy	 or	 rule promulgation	is	premature at	this	time

.

18 http://gotech.nmt.edu/gotech/Marketplace/year_prices.aspx?year=2013 19 In the President’s Climate report ordering EPA to complete the whitepapers, the Whitehouse assumes that completion of the papers would result in ‘robust technical understanding’ of the issues. IPANM contends that in every instance that the studies used and the lack of data does not give EPA regulators the required understanding of the issues to establish policy.IPANM	Comments: Liquids	Unloading	Processes Whitepaper June 13,	2014 Page 7 of 11

------------------------------------------------------------------ In	addition,	 IPANM	would	 urge	 the	 EPA	 to	 review and	 completely	 understand the information included	 in	 the	 National	 emissions	 inventory	 and	 information submitted pursuant	 to	 the	recently	promulgated	NSPS	SubPart	OOOO	amendments 20 .		This	data will provide	a	large amount	of	information	about emissions	at	oil	and	natural	gas	facilities but experts	 who	 understand	 industry must study	 and	 understand	 the	 information	 prior	 to establishing	policy

. 21 NSPS	SubPart	OOOO requires	 federal	air	 standards	 fo r	new	natural gas	 wells	 that	 are	 hydraulically	 fractured,	 along	 with	 requirements	 for	 several	 other sources	 of	 volatile	 organic	 compound	 (VOC)	 emissions	 from	 new	 storage	 vessels,	 newly installed	compressors,	pneumatic	controllers	and	equipment	leaks	at	nat ural	gas	facilities. Although	 the	 New	 Source	 Performance	 Standards	 directly	 regulate	 VOC	 emissions, in	 a Government	Accounting	Office	report	issued	May	16,	2014, the	EPA	reports	that	the	control require ments	 of	 NSPS	 SubPart	 OOOO substantially	 reduce s metha ne	 emissions 22

. C oncurrent	with	the	NSPS, in	April	2012,	EPA published	final	National	Emission	Standards for	 Hazardous	 Air	 Pollutants,	 updating	 its	 air	 toxics	 standards	 for	 oil	 and	 natural	 gas 23

. These	standards	cover	hazardous	air	pollutants	emitted	from	g lycol	dehydrators

— used	to remove	 water	 from	 gas

— and	 storage	 vessels,	 and	 equipment	 leaks	 at	 natural	 gas processing	 plants. Use	 of	actual	measurement	 from	locations	is	 obviously	 better	 towards

20 U.S. EPA, Oil and Natural Gas Sector: New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants Reviews Final Rule, 77 Fed .Reg. 49490 (Aug. 16, 2012) (codified at 40 C.F.R. Parts 60 and 63). 21 IPANM would urge the reviewers to look at the UT study that clearly explains differences in modeling based numbers used in the National Emissions Inventory versus actual measurements on location. We would caution against exclusive use of this study, however, since the measurements used were from shale formations only. See, Proceeding of the National Academy of Sciences of the United States of America (PNAS). 2013. Measurement of Methane Emissions at Natural Gas Production Sites in the United S tates. August 19, 2013. Available at http://www.pnas.org/content/early/2013/09/10/1304880110.abstract.. 22 GAO

- 14

- 238; Oil and Gas, Updated Guidance, Increased Coordination, and Comprehensive Data Could Improve BLM's Management and Oversight, page 23 23 77 F ed. Reg. 49490 (Aug. 16, 2012) (codified at 40 C.F.R. Parts 60 and 63).IPANM	Comments: Liquids	Unloading	Processes Whitepaper June 13,	2014 Page 8 of 11

------------------------------------------------------------------ building	an	understanding	of	the	issue	of	methane	emissions,	whi ch	is	what	we	believe	the agency	is	attempting	with	 the	recent	implementation	of	 the	NSPS	regulations.		We	would urge	 the	 EPA	 not	 to	 rush	 to	 creating	 regulations	 for	 all	 new	 and	 existing	 oil	 and	 gas locations	 to	 reduce	 methane	 emissions	 without	 a	 solid	 und erstanding	 of	 the	 actual impacts 24 of	methane	emissions	on	human	health	and	the	environment	or	the	actual	levels emitted	from	all	types	of	oil	and	gas	sources.
Specific	Comments BY	IPANM	Members to	April	2014	Whitepaper,	“ Oil	and	Natural	Gas Sector liqui ds	unloading	processes ” General	 Comment

– The	 oil	 and	 gas	 industry	 does	 not	 vent	 gas	 if	 there	 is	 an economic	way	to	capture	and	sell	the	gas.	We	are	in	the	business	of	selling	gas,	so	it	is	not	in our	best	interest	to	allow	gas	to	vent	to	the	atmosphere	i f	we	can	economically	sell	the	gas. 5.0	Charge	Questions	for	Reviewers
1. Please	 comment	 on	 the	 national	 estimates	 of	 methane	 emissions	 and	 methane emission	factors	for	liquids	unloading	presented	in	this	paper

. The	emissions	reported	in	the	EPA’s	Gree nhouse	Gas	Reporting	Program	for	plunger lift	venting	are	significantly	higher	than	actuals	due	to	the	required	calculation	method.	The calculation	method	 required	in	 Subpart	W	incorrectly	 assumes	 that	 the	 entire	 volume	 of the	tubing	is	vented	every	time	a well	on	plunger	lift	vents	to	atmosphere.	The	plunger	may travel	most	of	the	way	up	the	tubing	against	line	pressure,	but	can’t	make	it	all	the	way	to

24 Edwards, M. & Trancik, J., “ Climate Change of energy technologies depend on emissions timing” , Nature Clim. Change Letter, May 2014. T he actual impact of methane from different ener gy sources is substantially different than previously believed using the very simplistic GWP modeling. The MIT researchers advocate the use of dynamic modeling that better accounts for the differing radiative efficiencies and atomospheric lifetimes of diff erent gases. In essence, the comparison of gases must be dependent on the timing of the emissions. The researchers note that while it might be in vogue to tout the disasterous health effects of emissions from coal

fired plants as a policy determination to support natural gas plants, three decades from now, the emissions advantages of natural gas as compared to coal would be half of the levels claimed in the GWP modeling.IPANM	Comments: Liquids	Unloading	Processes Whitepaper June 13,	2014 Page 9 of 11

------------------------------------------------------------------ surface	 due	 to	inadequate	 reservoir	 pressure.	Many	 of	 our	 plunger	 wells	 only	 vent	 for	 a very	 short	 time to	 bring	 the	 plunger	 the	 rest	 of	 the	way	 to	 the	 surface.	But	 the	 required calculation	method	assumes	 the	entire	 tubing	 volume	was	 vented	whether	it	only	 vented for	 15	 seconds	 or	 20	 minutes. What	 factors	 influence	 frequency	 and	 duration	 of	 liquids unloading (e.g.,	regional	geology)? Every	well	is	different.	Yes,	a	high	reservoir	pressure	is beneficial,	but	there	are	many	other	 factors	that	can	have	an	impact	on	liquids	unloading. These	factors	include:	line	pressure,	consistency	of	the	line	pressure,	well	d epth,	amount	of liquids,	kind	of	liquid,	volume	of	gas,	and	tubing	size.
3. Is	this	only	a	problem	for	wells	further	down	their	decline	curve	or	can	wells	develop	liquids loading	problems	relatively	quickly	under	certain	situations? Many	new	wells	in	low er	pressure	or	depleted	reservoirs	require	liquids	unloading from	the	very	beginning.	Lower	volume	gas	wells	may	require	liquids	unloading	 from	the beginning. Are	 certain	 wells	 more	 prone	 to	 developing	 liquids	 loading	 problems,	 such	 as hydraulically	 fractu red	 wells	 versus	 conventional	 wells	 or	 horizontal	 wells	 versus	 vertical wells? There	 is	 no	 difference	 in	 liquids	 unloading	 between	 fractured	 wells	 and	 non

fractured	 wells,	 except	 the	 fractured	 wells	 generally	 produce	 at	 a	 higher	 rate	 allowing produced	liqu ids	 to	 be	carried	up	in	 the	gas	 stream.	The	 same	can	 be	 said	 for	horizontal wells.	The	higher	production	rates	may	have	enough	velocity	to	carry	produced	liquids	out in	 the	 gas	 stream,	 thus	 postponing	 liquids	 loading	 problems	 until	 later	 in	 the	 well’s	 life

. Once	liquid	unloading	is	required,	horizontal	wells	usually	do	not	use	plunger	lift,	because the	plunger	will	not	fall	past	about	65	degrees.	Non	venting	artificial	lift	such	as	rod	pumps, electric	submersible	pumps	or	hydraulic	pumps	are	normally	used	o n	our	horizontal	wells.IPANM	Comments: Liquids	Unloading	Processes Whitepaper June 13,	2014 Page 10 of 11

------------------------------------------------------------------ 4. Please	comment	on	the	costs	of	these	technologies. If	a	gas	well	will	not	free	flow,	the	liquids	unloading	technology	used	is	based	upon the	well’s	parameters	and	economics.	There	are	many	varia bles,	but	av erage	costs	for w ells in	the	San	Juan	Basin range	from	$20,000	for	a	plunger	list	and	$120,000	for	a	Rod	Pump versus	$170,000	for	an	ele ctric	submersible.

6. Are	there	situations	where	plunger	lifts	have	to	vent	to	the	atmosphere? Depending	 on	 the	 well’s	 characteristics	 an d	 line	 pressures,	 a	 plunger	 lift	 may require	venting	to	the	atmosphere.	It	is	obviously	in	industry’s	best	interest	to	operate	the plunger	lift	to	minimize	or	eliminate	this	venting,	but	it	is	not	always	possible.	Low	bottom hole	 pressure	 and	 high	 line	 pre ssure	 is	 not	 a	 good	 combination.	 Our	 operators	 make adjustments	 to	 cycle	 times,	 shut	 in	 times,	 etc.	 attempting	 to	 maximize	 production	 and eliminate	 or	 reduce	 any	 venting	 to	 the	 atmosphere,	 but	 there	 are	 situations	 that	 require venting.
9. Comment	on	the	p ros	and	cons	of	installing	a	“smart”	automation	system	as	part	of	a plunger	lift	system

. A	 “smart”	automation	 system	is	not	a	 cure

- all	 on	 venting	if	 the	 reservoir	 does	not have	 the	 pressure	 to	 bring	 up	 the	 plunger/water	against	line	 pressure,	 plus	 they	are not economic	on	all	wells.
13. Why	do	owners	and	operators	of	wells	choose	to	perform	blowdowns	instead	of	employing one	of	these	techniques? Many	times	periodically	blowing	down	a	well	to	remove	liquids	is	the	only	economic way	to	produce	a	low	volume well.	These	wells	would	not	economically	support	the	costs to	 install	 and	 maintain	 other	 forms	 of	 artificial	 lift.	 If	 not	 blowndown,	 the	 well	 wouldIPANM	Comments: Liquids	Unloading	Processes Whitepaper June 13,	2014 Page 11 of 11

------------------------------------------------------------------ eventually	 log	 off	 due	 to	 liquid	 buildup,	 and	 then	 would	 be	 prematurely	 plugged	 and abandoned	due	to	it	not being

IPANM	 thanks	 the	 EPA	 for	 the	 opportunity	 to	 comment	 on	 the	Oil	 and	 gas	 Sector Hydraulically	 Fractured	 Oil	 Well	 Completions	 and	 Associated	 Gas	 during	 Ongoing Operations	 whitepaper.	 We	 would	 be	 interested	 in	 participating	 in	 any stakeholder/taskforce /peer	 review	groups	 convened	 for	 the	 purpose	 of	addressing	 these policy	proposals.		We	look	forward	to	providing	additional	comments	as	the	agency	drafts of	 these	 proposed	 regulations	 materialize.	 	 Please	 feel	 free	 to	 contact	 me	 at Karin@ipanm.org or	at	(505)	238

- 8385	if	you	have	any	questions	regarding	the	issues.

Respectfully	submitted,
INDEPENDENT	PETROLEUM	ASSOCITION	OF	NEW	MEXICO

______________________________________________ By:	Karin	V.	Foster,	esq. Execut ive	Director