From: Akachi Imegwu/DC/USEPA/US

To: terri_shires@urscorp.com

Cc: Roger Fernandez/DC/USEPA/US@EPA, Kate Cardamone/DC/USEPA/US@ EPA, Ragan Tate/DC/USEPA/US@ E

Date: 05/17/2010 05:06 PM Subject: Re:Subpart W Cost Estimate

Hello Terri,

The Administrator signed a proposed supplemental rule on March 22, 2010 (75 FR 18608, April 12, 2010) to require reporting of greenhouse ga s (GHG) emissions from petroleum and natural gas systems ("proposed rule"). The comment period on the proposed rule closes on June 11, 2010. The proposed rule describes how official comments should be provided. To be considered, comments should be provided in the time and manner described therein. Any communication on the proposed rule before close of the comment period is intended to provide general and administrative information about the proposed rule. This communication does not provide legal advice, and responses to questions received do not have legally binding effect or expressly or implicitly create, expand, or limit any legal rights, obligations, responsibilities, expectations, or benefits in regard to any perso n. Facility owners or operators and suppliers are responsible for determining how they would be affected by the requirements of the rule.

EPA conducted extensive analysis on the various costs as sociated with the proposed rule. Complete details of the economic impacts of t he proposed rule can be found in the text of the Economic Impact Analysis for the Mandatory Re porting of Greenhouse Gas Emissions under Subpart W Supplemental Rule. In addition, fu rther related information can be found on EPA's reporting threshold analysis in the related Technical Support Document. See, http://www.epa.gov/climatechange/ emissions/subpart/w.html

Sincerely,

____________________________ Akachi N. Imegwu Climate Change Division

Office of Air and Radiation US Environmental Protection Agency p(202) 343-9709

Any communication on the mandatory GHG reporting rule is intended to provide general and

administrative information about the Rule. This communication does not provide legal advice, and responses to questions received do not have legally binding effect or expressly or implicitly create, expand, or limit any legal rights, obligatio ns, responsibilities, expectations, or benefits in regard to any person. Facility owners or operat ors and suppliers are responsible for determining how they would be affected by the requirements of the rule.

----- Original Message -----

From: Terri_Shires

Sent: 05/11/2010 02:53 PM ASTTo: MRRproposed

Cc: Roger Fernandez; Carole Cook; ritterk@api.org Subject: Subpart W Cost Estimate



### American Petroleum Institute members have examined the EIA analysis associated with Subpart W to understand the basis

for the 4% value in Table W-2 that indicates 4% of "facilities" are covered by the rule at the 25,000 tonnes CO2e threshold and the basin definition for facility. As shown in Table W-2, 4% represents 1,232 "facilities" out of

a total of 27,993 "facilities" that would have to report under subpart W. We assume that the 27,993 “facilities” equates to the sum of the number of operators in each basin and is not reflective of the number of wells potentially covered if all 27,993 “facilities” were covered (~750,000 wells).

Table W-2 also shows that this 4% of "facilities" account for 81% of the emissions. We are struggling to understand

how 4% of "facilities" can account for 81% of emissions without covering 81% of the individual sites/wells. We request EPA to provide details on how this conclusion was

made , since in our view, 81% of the emissions would also be represented by roughly the same percentage of wells (~607,500 wells)!

Neither the EIA nor the preamble to subpart W explain in detail how these “facility” counts were determined, and how

the emissions were allocated to these "facilities" to

evaluate the different thresholds. We request EPA to provide the supporting details on the allocation of emissions to "facilities" as defined in the proposed rule. In particular, please provide the "equipment activity (that) was estimated at the field-level and aggregated to the national level then apportioned to individual operators in basins by production rates" as mentioned in the EIA (page 4-
5).

Sincerely

Terri Shires

_________________________

URS Corporation - Austin

Terri_Shires@URSCorp.com (512) 419-5466 - Office (512) 497-6482 - Cell (512) 454-8807 - Fax

_________________________

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