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 gas (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 person. 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 associated with the proposed rule. 

Complete details of the economic impacts of the proposed rule can be found in the text of the 

Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions under 

Subpart W Supplemental Rule. In addition, further 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, obligations, responsibilities, expectations, or benefits in 

regard to any person. Facility owners or operators 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 AST 
 To: 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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