Clean Air Task Force * Earthjustice * Environmental Defense Fund * 

Natural Resources Defense Council * Sierra Club * 

Western Environmental Law Center * WildEarth Guardians 

July 22, 2011 

Lisa Jackson 

Administrator 

U.S. Environmental Protection Agency 

Ariel Rios Building 

1200 Pennsylvania Ave., NW 

Washington, D.C. 20460 

Re: Request for Public Hearings in Oil and Gas Clean Air Act Rulemaking 

Dear Administrator Jackson: 

We are writing to request that EPA hold public hearings for its proposed revisions to the New 

Source Performance Standards (“NSPS”) and National Emissions Standards for Hazardous Air 

Pollutants (“NESHAP”) for the oil and natural gas sector. The rules will benefit the thousands 

and thousands of people across the country who are now suffering from the industry’s air 

pollution. EPA should make sure that their voices are clearly heard in this rulemaking. 

As an initial matter, we thank you for taking urgently needed steps to safeguard public health 

and welfare from air pollution associated with oil and natural gas development through 

updates to the Clean Air Act’s NSPS and NESHAP. We understand the EPA is on track to 

propose updates by the end of July and to finalize any revisions by the end of January 2012. As 

you know, there are tremendous opportunities to ensure that cost-effective emissions controls 

are utilized more broadly by the industry in order to ensure lasting protection of public health, 

welfare, and our economic prosperity. 

We understand the EPA may be weighing options for public hearings in conjunction with the 

NSPS and NESHAP updates after any proposed rules are released in July, and that the locations 

may include Denver, Arlington, Texas, and Pittsburgh. We support the agency’s efforts to hold 

public hearings in these cities given their proximity to major oil and gas producing areas. We 

trust that you will finalize these hearing dates and locations soon. We also urge you to 

investigate ways to enable participation by affected and concerned citizens who do not live 

near these cities and cannot afford to travel to them, as many other parts of the country face 

serious pollution threats from the oil and gas industry. Many of the affected populations are 

low income communities and communities of color, whose voices in the process are of special 

concern and value. For instance, tribal populations in Alaska are particularly affected by the oil 

and gas industry, and would face exceptional costs in traveling to the lower 48 states. EPA 

should consider, for example, offering video conferencing access to its hearings, and using 

social media to aid participation by as many members of the public as possible. 
As organizations that represent millions of members across the country, many of whom are 

increasingly voicing to us their concerns over the air quality impacts of oil and gas development, 

we appreciate your time and attention to this letter and our request. We look forward to 

working with EPA to ensure that the final rules are as strong as possible. Thank you. 

Sincerely, 

Deb Nardone 

Director, Natural Gas Reform Campaign 

Sierra Club 

PO Box 1363 

State College, PA 16804 

Deb.Nardone@sierraclub.org 

Craig Holt Segall 

Attorney 

Sierra Club 

50 F St NW, Eighth Floor 

Washington, DC, 20003 

Craig.Segall@sierraclub.org 

Ann Brewster Weeks 

Senior Counsel, Legal Director 

Clean Air Task Force 

18 Tremont Street, Suite 530 

Boston, MA 02108 

aweeks@catf.us 

Robin Cooley 

Attorney 

Earthjustice 

1400 Glenarm Place, #300 

Denver, CO 80202 

Rcooley@earthjustice.org 

Ramón Alvarez, Ph.D. 

Senior Scientist 

Environmental Defense Fund 

44 East Ave, Suite 304 

Austin, TX 78701 

ralvarez@edf.org 

Meleah Geertsma 

Attorney 

Climate Center and Clean Air Program 

Natural Resources Defense Council 

1152 15th Street, NW, Suite 300 

Washington, D.C. 20005 

mgeertsma@nrdc.org 

Erik Schlenker-Goodrich 

Director, Climate and Energy Program 

Western Environmental Law Center 

208 Paseo del Pueblo Sur, Unit 602 

Taos, New Mexico 87571 

eriksg@westernlaw.org 

Jeremy Nichols 

Climate and Energy Program Director 

WildEarth Guardians 

1536 Wynkoop, Suite 301 - Denver, CO 80202 

jnichols@wildearthguardians.org