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OVERVIEW OF COMMENTS ON EPA'S PROPOSED AIR RULES (2015) 

Anadarko Petroleum Corporation - An Industry Leader 

December l , 2015 

Anadarko Petroleum Corporation is one of the nation's leading producers of clean-burning natural gas. We are 

among the world's largest independent oil and natural gas exploration and production companies operating 

approximately 25,000 wells in the United States. Anadarko's onshore U.S. operations are located in the Rocky 

Mountain areas, the southern U.S., the Appalachian basin and Alaska. We are proud that our company's voluntary 

actions and collaborative approach with regulators and other stakeholders are resulting in cleaner air, fewer 

emissions and more of our product reaching our customers. 

Our company has played a transformative role in how energy resources are bring produced, which includes 

implementing emission-reduction technologies and best practices across our operating areas. We also focus on 

improving the science around methane emissions through studies· with respected academic institutions and the 

Environmental Defense Fund. We demonstrated our support for the collaborative, constructive and state-led 

approach that resulted in Colorado's revision of Regulation No. 7 on air quality. 

These constructive and collaborative efforts are reducing emissions and ensuring natural gas remains abundant and 

affordable as it continues to be the most reliable and scalable option available for achieving U.S. carbon-reduction 

targets. We encourage the Environmental Protection Agency (EPA) to continue to enhance the opport unities to 

provide companies incentives for early action, including by providing states the maximum flexibility in developing 

their programs. 

Source Determination: Proposed Rule Determination for Certain Emission Units in the Oil and Natural Gas Sector, 

40 C.F.R. Parts 49, 51, 52, 70, 71 

Federal and state emission control requirements for upstream oil and natural gas facilities are based on the type of 

equipment installed. The type of equipment on-site will not change based on the aggregation of locations. The 

proposal will simply change the complexity of permitting with negligible air quality improvements. 

This proposed rule will overwhelm permitting agencies with permit applications and permit modification 

applications; permits will not be issued in a predictable timeframe causing delays for oil and natural gas 

development and great regulatory uncertainty. 

Anadarko agrees clarification will help both the regulators and regulated community, but that clarification should 

comport with the CAA language and case law. Anadarko is proposing the following alternative language to provide 

the balance: 

"Contiguous or adjacent properties" mean surface areas with an affixed building, structure, facility 

or installation including permanently graded or cleared areas for such building, structure, facility or 

installation, that share an edge/boundary, physica lly touch, and are adjoining or physically abutting. 

As proposed, the rule suffers from a number of legal flaws that will subject the rule to legal challenge and possibly 

more uncertainty. We believe this is the not the objective of EPA, nor the desire ofthe regulated community. EPA 

should ensure the rule is addressing the legal concerns raised in comments, and work directly with the oil and 

natural gas sector to develop the appropriate guidance. 

This rulemaking: (1) offers minimal to no environmental benefit; (2) fails to evaluate the economic impacts required 

under the Clean Air Act (CAA); and (3) significantly increases administrative burden, costs, delays and inefficiencies 

to permitting programs nationwide. 
New Source Performance Standard (NSPS) Subpart OOOOa: Proposed Rule Standards of Performance for New 

Stationary Sources: Oil and Natural Gas Production and Natural Gas Transmission and Distribution 

We share the concerns of our industry that EPA's one-size-fits-all proposed methane regulations would significantly 

and unnecessarily increase costs. Such an approach will also carry the unintended consequence of curbing further 

emission reductions by discouraging voluntary, collaborative and state-based solutions that have proven successful 

in encouraging innovation and improving our industry's environmental performance. 

We support EPA's stated objectives to achieve the most reductions with the least regulatory burden. However, the 

proposed rulemaking deviates from this stated goal on a number of levels. Among the most notable, is the proposal 

by EPA to impose a leak detection and repair (LDAR) program on states that already have legally and practicably 

enforceable programs. The rule should provide states the ability to develop a state-specific LDAR program. The 

federal rulemaking can provide general principles for a program, without prescriptive requirements dictating the 

components of a state program. The rule should further affirm that a state with an existing LDAR program that 

meets the general principles, also meets the requirements of the federal rule. 

Federal Implementation Plan (FIP} for Managing Air Emissions from True Minor Sources Engaged in Oil and 

Natural Gas Production in Indian Country 

As written, this particular rule has limited utility since it can only be utilized in attainment areas and for true minor 

sources. The FIP should be modified to: 

• Include a plan for areas transitioning from attainment to nonattainment; 

• Provide a streamlined mechanism for synthetic minors; and 

• Allow for a pre-construction registration and post-production emission calculations. 

Natural Gas STAR Methane Challenge 

This voluntary program comes on top of the ongoing aforementioned rule makings and other regulations for the oil 

and natural gas industry, which include: lowered Ozone National Ambient Air Quality Standard, expanded 

greenhouse gas (GHG) reporting rule, Bureau of Land Management tracking rule, GHG regulation of new and 

existing utilities, Refinery Sector Rule, Council on Environmental Quality guidance on addressing climate change 

under the National Environmental Policy Act, and Waters of the US. 

With all the other regulatory activities, at this time, it will be difficult for industry to find incentives or the resources 

to pursue voluntary measures as reflected in the Methane Challenge. To date, EPA has not adequately created 

synergy between its voluntary program and numerous other regulatory initiatives. Program participation could be 

increased if EPA takes a more holistic view of the burdens it is imposing on industry and develops a program that 

provides a business justification. We encourage EPA to collaborate with industry around voluntary programs that 

maximize methane reductions without the burden of formal regulatory initiatives that are limited in focus and 

effectiveness. 


Legend 

e Production Facility 

1/4 mile Production Facility Buffer 

Date created: 11/2/2015 

Scale: 1:6,000