Good morning. My name is Matthew Todd and I’m a senior policy advisor at the

American Petroleum Institute. API represents more than 500 oil and natural gas

companies, leaders of a technology-driven industry that supplies most of

America’s energy, supports 9.2 million U.S. jobs and 7.7 percent of the U.S.economy, and delivers more than $86 million a day in revenue to our

government. Our industry plays a vital role in meeting the energy demands of ournation and many of our members will be directly impacted by the outcome of this

regulation.

I should start by saying that API has been actively engaged throughout the

development of the Oil and Natural Gas Sector New Source Performance

Standards, to advocate for a final rule that is cost-effective, achievable and would

not inadvertently jeopardize the safety of our operators in any way. To that end,

we have worked to identify cost-effective technologies to achieve the emissionreductions the EPA was seeking and to ensure sufficient time to implement the

rule so as not to impede operations or create undue compliance risk. It’s also

important to note that this regulation is a major expansion of the existing NSPS
y

p

of the storage tank requirements as published was simply going to be an

impossible task. API estimates that there are tens of thousands of tanks that

would be affected by this rule since the 2011 proposal date and simply not

enough emission controls to install by the October deadline. Subsequently, API

filed a petition for reconsideration of the final rule to address this implementation

issue in hopes of arriving at a common sense solution that will allow industry

adequate time to implement the rule. These changes are critical to avoid

unnecessary compliance complications and interruption to operations that will

arise this fall if the rule does not change. Again, API members do not object to

controlling emissions from these tanks; however, the controls should be

implemented on a timeframe and with enough flexibility appropriate for a source

category with tens of thousands of affected sources now, and the thousands of

new tanks that are expected to be installed each year, year after year.

The proposed rule under discussion today appears to address these concerns and

we believe the Agency has put forth an approach that makes sense by requiring
construct of the proposed rule, API plans to submit some recommendations to

add clarity to tracking the Group 1 tanks. For example it will be critical to make

very clear what emission events will cause the Group 1 tanks to follow the Group

2 requirements. In addition, API is supportive of the proposed compliance

assurance requirements that confirm the emissions controls are in place and

functioning properly and believes this approach could, and should, apply to other

sources.

In closing, we agree with the President’s statements that the development of

natural gas is a job creator and that we don’t have to choose between the

environment and our economy. And while some may say that EPA should regulate

everything and regulate it now, it’s quite another thing for our industry to

implement, and the EPA to track, a rule that will ultimately impact and reduce

emissions from hundreds of thousands of sources, many of which, as you know,

are in extremely remote and unmanned locations. We commend the Agency for

trying to strike that balance throughout this effort. The proposal significantly

improves the rule and makes it more achievable. It gives industry a chance to
Thank you for providing me this opportunity to deliver testimony on this very

important regulation.