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 Completions: Hydraulically	Fracture d	oil	wells Whitepaper Dear	Sir	or	Madam;
The	 Independent	Petroleum	Association	of	New	Mexico	 (‘IPANM’)	apprec iates	 this opportunity	to	comment	to	the EPA	Office	of	Air	Quality	Planning	&	Standards	(hereinafter ‘EPA’)	whitepaper	on	Oil	and	Gas	Sector Completions:	Hydraulicall y	Fractured	oil	wells of April	2014

. Preliminary	matters: Without	adequate	research	and a n expert understanding	of the	issues,	it	would	be
unethical	 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	 dyn amic. In	 fact, since	 the introduction	 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	eq uivalent	scale should	beIPANM	Comments: Completions	Oil	Wells Whitepaper June	13,	2014 Page 2 of 12

------------------------------------------------------------------ the	accepted	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	Ch ange stating	that	the	sta tic	nature	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	2016,	 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	studies	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	Procedures	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	o perations	in	 the	San	 Juan
and	 Permian	 basins. Within	 the	 PRRC	 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	Labor atory.	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 i nfluenced a ‘major piece of environmental legislation’ (Kyoto Protocol) that could impact ‘big investment and policy. ’ 3 Edwards, M. & Trancik, J., “ Climate Change of energy technologies depend on emissions timing” , Nature Clim. Change Letter, May 2014,IPANM	Comments: Completions	Oil	Wells Whitepaper June	13,	2014 Page 3 of 12

------------------------------------------------------------------ chosen	 to	 lea d	 the	 SP	 program	 because	 of	 their track	 record of	 research	 and	 actions	 on behalf	of	small	oil	and	gas	producers,	 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	Association	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	multi ple	proverbial	hats,	but	we provide	enough	revenue	to	the	State	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 ranki ng	New	Mexico	sixth	in	crude	oil	production	in
the	nation	in	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

. Accordin g	 to	 the	 Office	 of	 Natural	 Resources	 Revenue,	 in	 FY 2013	 the	 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.state.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: Completions	Oil	Wells Whitepaper June	13,	2014 Page 4 of 12

------------------------------------------------------------------ The	 process	 by which	 these	whitepapers	were	 developed	was	 flawed	 and	 requires	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	 expanded 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	 Envi ronmental	 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 Administration’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 EPA 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., authorizes federal regulation of emissions of carbon dioxide and other greenhouse gases, including methan e. 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 se ttled 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 rep orted 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%. Insignificant

. 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_emissions_2014

- 03

- 28_final.pdf ,IPANM	Comments: Completions	Oil	Wells Whitepaper June	13,	2014 Page 5 of 12

------------------------------------------------------------------ promulgate	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	from “oil
and	 co

- producing	wells,	liquids	 unloading,	leaks,	 pneumatic	 devices	and	 compressors” to “solicit	 input	 from	 independent	 experts 16 ” (hereinafter	 refe rred	 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 n ot one single	 small	 independent was included	 o n	 any	 panel

. It	 is	 interesting	 to	 note	 that	 the Environmental	 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	 constraints,	 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	 oth er	 as	 ‘science’

. Of	 the	 few	 studies	 the	 EPA	 relied	 upon,	 every

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

. 15 The BLM Venting an d 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 information 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 Research Recovery Center or RPSEA who are the entities often commissioned for su ch work.IPANM	Comments: Completions	Oil	Wells Whitepaper June	13,	2014 Page 6 of 12

------------------------------------------------------------------ whitepaper referenced a	 study	 commissioned	 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	tru e	costs	which,	by	IPANM	member	review, were well in	excess	of	$10,000	per
well because	 of	 the equipment	 rental,	 mileage,	 time and	 personnel	 time	 to	 operate	 the equipment.			As	noted	earlier	in	this	comment,	the	small	producer	has	significantly	different

ec onomics	 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

extra polated	 to	 estimate	 savings	 on	 a	 nationwide	 basis	 renders	 the	 EDF	 study	 close	 to meaningless	 as	 a	 foundation	 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	 on	 these	 very	 complex	 matters

. IPANM	 contends	 that	 based	 on	 the inadequate	 information	 reviewed , that	 the	 EPA	 does	 not	 have	 any	 sort	 of	 a	 ‘robust
understa nding 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 understand ing’ 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: Completions	Oil	Wells Whitepaper June	13,	2014 Page 7 of 12

------------------------------------------------------------------ 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	 w ho	 understand	 industry must study	 and	 understand	 the	 information	 prior	 to establishing	policy

. 21 NSPS	SubPart	OOOO requires	 federal	air	 standards	 for	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	natural	gas	facilities. Although	 the	 New	 Source	 Performance	 Standards	 directly	 regulate	 VOC	 emissions, in	 a
Go vernment	Accounting	Office	report	issued	May	16,	2014, the	EPA	reports	that	the	control require ments	 of	 NSPS	 SubPart	 OOOO substantially	 reduce s methane	 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	glycol	dehydrators

— used	to remove	 water	 from	 gas

— and	 storage	 vessels,	 and	 equipment	 leaks	 at	 natural	 gas
p rocessing	 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, how ever, 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 States. Aug ust 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 Fed. Reg. 4 9490 (Aug. 16, 2012) (codified at 40 C.F.R. Parts 60 and 63).IPANM	Comments: Completions	Oil	Wells Whitepaper June	13,	2014 Page 8 of 12

------------------------------------------------------------------ building	an	understanding	of	the	issue	of	methane	emissions,	which	is	what	we	believe	the agency	is	attempting	with	 the	recent	implementation	of	 the	NSPS	regulations.		W e	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	 understanding	 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	Hydraulically	Fractured	Oil	Well	Completions	and	Associated	Gas	during	Ongoing Production ” Preliminary	commen t: If	the	States	share	responsibility	for	air	quality,	any	regulation	or	permitting	should be	at	the	State	level.		Since	flaring	is	a	short

- term	event,	until	infrastructure	is	built, permitting	should	be	simple	and	dovetail	with	existing	rules. Question :		Why	is	the	EPA	declining	to	define	what	an	‘oil	well’	is	for	purposes	of methane	emissions?

1. Page	4,	paragraph	3	“very	high	pressure”	A	large	portion	of	the	observed	surface pressure	is	lost	due	to	friction	in	the	“treating	conduit”,	so	the	BHTP	is much	lower.

2. Page	4,	paragraph	3	“water	emulsion”	is	not	a	correct	term.	Most	frac	fluid	is	water with	a	viscosifier,	such	as	guar	gum,	added	to	increase	viscosity.

3. Page	12,	last	paragraph,	during	a	typical	load	recovery,	only	small	amounts	of	oil and	gas are	recovered	until	approximately	half	of	the	load	is	recovered.

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 energy 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 different gase s. 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 n atural 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: Completions	Oil	Wells Whitepaper June	13,	2014 Page 9 of 12

------------------------------------------------------------------

4. Page	12,	paragraph	2,	a	recompletion	may	have	minimal	emissions	if	the	producing equipment	and	pipeline	are	in	place.

5. Page	27,	5.2	Completion	Combustion	Devices

– Combustion	devices	are	us ed	as	a safety	measure	to	prevent	gas	from	collecting	that	would	be	in	the	combustible range	imposing	a	safety	hazard.

6. Page	30,	5.3.1	NGL	Recovery

– short	term	small	scale	NGL	recovery,	storage	and transportation	facilities	are	uneconomical.

7. Page	35,	5.3 .2	Natural	Gas	Reinjection

– Gas	reinjection	requires	one	or	more injection	wells	and	a	large	investment	in	compression.	Also,	“tite”	formations	such as	the	Bakken	do	not	have	sufficient	permeability	to	allow	large	volumes	of	gas	to	be injected	and	to	be	m obile	within	the	reservoir.

8. Page	38,	5.5.3	Electrical	Generation

– Relative	small	volumes	of	gas	are	needed	for onsite	electrical	needs,	20	MCFD	will	generate	approximately	100	H.P.	Also, electrical	infrastructure	in	remote	locations	cannot	accommodate	la rge	volumes	of excess	electrical	power. 7.0	Charge	Questions	for	Reviewers 1. Please comment on the national estimates and per well estimates of methane and VOC emissions from hydraulically fractured oil well completions presented in this paper. Are there factors that influence emissions from hydraulically fractured oil well completions that were not discussed in this paper? The	 reservoir	 G.O.R.	 varies	 widely	 for	 different	 reservoirs.	 The	 reservoirs	 used	 in this	study	are	typically	high	G.O.R.	hydrocarbon systems.
2. Most available information on national and per well estimates of emissions is on uncontrolled emissions. What information is available for emissions, or what methods can be used to estimate net emissions from uncontrolled emissions data, at a national a nd/or at a per well level? To	be	accurate,	data	needs	to	be	on	a	per	well	level. 3. Are further sources of information available on VOC or methane emissions from hydraulically fractured oil well completions beyond those described in this paper? Yes,	but it’s	hard	to	acquire	and	is	not	complete.IPANM	Comments: Completions	Oil	Wells Whitepaper June	13,	2014 Page 10 of 12

------------------------------------------------------------------ 4. Please comment on the various approaches to estimating completion emissions from hydraulically fractured oil wells in this paper.

§ Is it appropriate to estimate average uncontrolled oil well completion emiss ions by using the annual average daily gas production during the first year and multiplying that value by the duration of the average flowback period?

§ Is it appropriate to estimate average uncontrolled oil well completion emissions using “Initial Gas Pr oduction,” as reported in DI Desktop, and multiplying by the flowback period?

§ Is it appropriate to estimate average uncontrolled oil well completion emissions by increasing emissions linearly over the first nine days until the peak rate is reached (norm ally estimated using the production during the first month converted to a daily rate of production)?

§ Is the use of a 3

- day or 7

- day flowback period for hydraulically fractured oil wells appropriate? Load	recovery	and	testing	may	take	a	few	days,	a	few weeks	or	a	few	months,	every
well	is	different.

5. Please discuss other methodologies or data sources that you believe would be appropriate for estimating hydraulically fractured oil well completion emissions. Individual	well	tests 6. Please comment on the methodologies and data sources that you believe would be appropriate to estimate the rate of recompletions of hydraulically fractured oil wells. Can data on recompletions be used that does not differentiate between conventional oil wells and hydraulically fractured oil wells be reasonably used to estimate this rate? For example, in the GHG Inventory, a workover rate of 6.5% is applied to all oil wells to estimate the number of workovers in a given year, and in the ERG/ECR analysis a bove a rate of 0.5% is developed based on both wells with and without hydraulic fracturing. Would these rates apply to hydraulically fractured oil wells? For hydraulically fractured gas wells, the GHG Inventory uses a refracture rate of 1%. Would this rate be appropriate for hydraulically fractured oil wells? More	mature	areas	should	have	a	higher	recompletion	rates. 7. Please comment on the feasibility of the use of RECs or completion combustion devices during hydraulically fractured oil well completion operations. Please be specific to the types of wells where these technologies or processes are feasible. Some characteristics that should be considered in your comments are well pressure, gas content of flowback, gas to oil ratio (GOR) of the well, and a ccess to infrastructure. If there are additional factors, please discuss those. For example, the Colorado Oil and Gas Conservation Commission requires RECs only on “oil and gas wells where reservoir pressure, formation productivity and wellbore conditions are likely to enable the well to be capable of naturally flowing hydrocarbon gas in flammable or greater concentrations at a stabilized rate in excess of five hundred (500) MCFD to the surface against an induced surface backpressure of five hundred (500) p sig or sales line pressure, whichever is greater.”IPANM	Comments: Completions	Oil	Wells Whitepaper June	13,	2014 Page 11 of 12

------------------------------------------------------------------ Gas	volumes	need	to	be	sufficient	to	justify	REC’s.	Combustion	devices	can	be	used on	most	 wells	 and	most	 areas	 have	 suppliers	 that	 can	 rent	 or	lease	 equipment	 for	 short periods	of	time.
8. Please commen t on the costs for the use of RECs or completion combustion devices to control emissions from hydraulically fractured oil well completions. Depending	 on	 the	 distance	 to	 a	 pipeline	 and	 processing/separation	 requirements, REC’s	are	multiply	times	more	expen sive	than	combustors.
9. Please comment on the emission reductions that RECs and completion combustion devices achieve when used to control emissions from hydraulically fractured oil well completions. Rec’s and	combustion	devices	can	reduce	emissions	by	+95%.
10. Please comment on the prevalence of the use of RECs or completion combustion devices during hydraulically fractured oil well completion and recompletion operations. Are you aware of any data sour ces that would enable estimating the prevalence of these technologies nationally? My	experience	is,	on	any	completion	that	produces	gas	a	REC,	combustion	device	or flare	is	used	 to	prevent	a	 safety	hazard	and	 safely	dispose	 of	produced	gas.	 I	 know	 of	no
d ata	sources	to	estimate	these	technologies	nationally. 11. Did the EPA correctly identify all the available technologies for reducing gas emissions from hydraulically fractured oil well completions or are there others? EPA	identified	the	available	technol ogies.

12. Please comment on estimates of associated gas emissions in this paper, and on other available information that would enable estimation of associated gas emissions from hydraulically fractured oil wells at th e national

- and the well

- level Applyi ng	a	small	data	set	nationally	has	inherent	errors. 13. Please comment on availability of pipeline infrastructure in hydraulically fractured oil formations. Do all tight oil plays (e.g., the Permian Basin and the Denver

- Julesberg Basin) have a similar lack of infrastructure that results in the flaring or venting of associated gas? Some	areas	have	pipelines	close	to	new	areas	and	some	don’t. 14. Did the EPA correctly identify all the available technologies for reducing associated gas emissions from hydrauli cally fractured oil wells or are there others? Please comment on the costs of these technologies when used for controlling associated gas emissions from hydraulically fractured oil wells. Please comment on the emissions reductions achieved when these tech nologies are used for controlling associated gas emissions from hydraulically fractured oil wells. See	#11,	#7,	#8	and	#9.IPANM	Comments: Completions	Oil	Wells Whitepaper June	13,	2014 Page 12 of 12

------------------------------------------------------------------ 15. Are there ongoing or planned studies that will substantially improve the current understanding of VOC and methane emissions from hydraulically fractured oil well completions and associated gas and available options for increased product recovery and emission reductions? Unknown.

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	providi ng	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. Executive	Director