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# IOVERVIEW OF COM M ENTS ON EPA' S PROPOSED AIR RULE S 

### (2015) An adarko Petro l e u m Corpo rati on - An Industry L ea d er Decembe r 

### l , 201 5 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 i n the Un ited States. Anadarko's onshore U.S. operations a re 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 regu lators and other stakeholders are resulting in cleaner air, fewer emissio n s and mo re of our p roduct 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 operati ng 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 encou rage the Environmental Protection Agency (EPA) to continue to enhance the oppo rt u nities to provide companies incentives for early action, including by providing states the maximum flexibility in developing their programs . Source Dete rmin ation: Proposed Rul e 

### D e ter minat ion for Ce rtain Emissi on Un its in th e Oil and Natural Gas Sector , 40 C. F . R. P a rts 49, 

### 51 , 52 , 70 , 71 Federal and state emission control requirements for upstream oi l and natural gas facil ities 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 modificati on 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 insta ll ation, that share an edge/boundary, physi ca lly touch, and are adjo in ing or physica ll y abutti ng. 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 lega l concerns raised in comments, and work directly with the oil and natural gas sector to develop the appropriate guidance. This rulemaking: (1) offers min i mal to no envi ronmenta l 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 P e rformance Standard (NSPS) Subpart OOOOa: Proposed Rul e Standard s ofPerformance for New Stationary Sources: Oil and Natural Gas Production and Natural Gas Transmi ssion and Distribution We share the conc ern s of our industry that EPA's one -size-fits-a ll proposed methane regulations wou ld significantly and unnecessarily in crease costs. Such an approach wi ll also carry the unintended co nsequence of curbing further emission reductions by discouraging voluntary, collaborative and state- based so lutions that have proven successfu l in en co uraging 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 im pose a leak detecti o n and repa i r (LDAR) program on states that already have lega lly and practicably enforceable programs. The rule should provide states the ability to develop a state-specific LDAR program. The federal rulemaking can provid e ge neral principles for a program, without prescriptive requirements d i ctating the co mponents of a state program . The rule should further affirm that a state with an exist ing LDAR prog ram that meets the general principles, also meets the requirements of the federal rule . Federal Impleme ntation Plan (FIP} for Managing Air Emission s from True Minor Sources Engaged in Oil and Natural Gas Production in Indian Country As written , this particu l ar ru le has l imited utility since it c an only be utilized in atta in ment areas and for true minor sources. The FI P should be modified to: • Include a plan fo r areas t ransition ing from attainm e nt to no nattain ment ; • Provide a streamlined mechanism for synthetic minors; and • Allow for a pre-construction re gi stration and post- production emission calculations. Natural Gas STAR Methane Challeng e This vo lu ntary program co m es on top of the ongoi ng afo rem e nti oned rule makings and other reg ulat io ns fo r the oil and natural gas ind ustry, which i nclude : lowered Ozone National Ambient Ai r Quality Standard, expanded g reenhou se gas (GHG) report ing rule, Bureau of Land Manage ment track in g rule, GHG regulation of new and existing utilities, Refinery Sector Rule , Council on Environmental Quality guidance on addressing cl imate change under the National Environmental Po licy Act, and Waters of the US . With all the other regulatory activities, at this time, it will be difficult for ind ustry to find incentives or the resou rces to pursue voluntary measures as reflected in the Methane Challenge. To date , EPA has not adequately created syne rgy between its voluntary program and numerous ot her reg ulatory initiatives. Prog ram participation could be increased if EPA takes a more holistic view of the burdens it is imposing on industry and develops a prog ram that provides a business ju stificat ion. We encou rage EPA to collaborate with industry around voluntary prog ram s that maximize methane reductions without the burden of formal regulatory initiatives that are l imited in focus and effectiveness.Legend e Production Facility 1/4 mile Produ c t io n Facility Buffer Date created

: 11/2/2015 Scale

: 1:6,000