1



### Environmental Protection Agency 1

2

3



### EPA Docket Number EPA

- HQ

- OAR

- 2014

- 0831 4

5


### Public Hearing on 6


### Greenhouse Gas Reporting Rule: 7


### 2015 Revisions and Confidentiality 8



### Determinations for Petroleum and 9



### Natural Gas Systems 10

11

12

13



### 9:11 to 10:12 a .m. 14



### Thur sday, January 8 , 201 5 15

16


### U.S. Environmental Protection Agency 17



### Room 1153 18



### 1201 Constitution Avenue, N.W. 19


### Washington, D.C. 20004 20

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### EPA PANEL: 1


### PAUL GUNNING, Presiding Official, 2


### Director, Climate Change Division, EPA 3



### ANHAR KARIMJEE, Branch Chief, 4


### Greenhouse Gas Reportin g Program, EPA 5



### ALEXIS McKITTRICK, 6


### Technical Subject Matter Expert, 7


### Greenhouse Gas Reporting Program, EPA 8

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### C O N T E N T S 1



### PAGE 2



### THOMAS BACH, Director, 3


### Environmental Services, Kinder Morgan, 4



### R epresenting Interstate Natural Gas 5



### Association of America 7 6



### KARIN RITTER, Manager, 7


### Regulatory and Scientific Affairs Department, 8



### American Petrol eum Institute 16 9

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### P R O C E E D I N G S 1



### MR. GUNNING: It is cold, and it is a big 2



### room. The closer you get together, the warmer 3


### you will be. 4


### Anyway, in case you are wanting to know 5


### where you are and making sure you are at the 6


### right place, this is a hearing on the proposed 7


### rule, greenhouse gas reporting rul e, 2015 8


### revisions and confidentiality determinations for 9



### petroleum and natural gas systems, Subpart W. 10


### I am Paul Gunning. I am the Director of 11


### the Climate Change Division at EPA, and I will be 12


### presiding over the hearing this morning. 13



### I also have a cou ple colleagues

-- I will 14



### allow them to introduce themselves

-- that will 15


### be joining us today. 16


### MS. KARIMJEE: Good morning. I am Anhar 17


### Karimjee, and I am the Branch Chief for the 18


### Greenhouse Gas Reporting Program. 19



### MS. McKITTRICK: Alexis McKittrick with 20



### t he Greenhouse Gas Reporting Program. 21



### MR. GUNNING: So the purpose of the 22

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### hearing today, as many of you know, is to receive 1


### comments on the proposed rule, which again was 2


### published in the Federal Register back on 3



### December 9th, 2014. 4


### This hearing is being conducted in 5



### accordance with the Clean Air Act under which EPA 6


### provides interested persons the opportunity for 7


### all presentation of the views and arguments as 8


### well as the opportunity to submit written 9


### comments. The hearing today provides a forum for 10



### those oral presentations. 11


### I want to make sure everybody is aware 12


### that we are having the hearing recorded. There 13


### is a transcript that will be available for public 14


### inspection and copying in the docket, the Docket 15



### Number, the EPA Docket Number, EPA

- HQ

- OAR

- 2014

- 16



### 08 31. 17


### The transcript, of course, will be also 18


### available electronically on the regulations.gov 19



### website in the same docket. 20


### This morning, we are going to conduct the 21


### hearing informally, and Formal Rules of Evidence 22

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### do not apply. However, as the presiding of ficer, 1


### I will let you know that I am authorized to 2



### enforce reasonable limits on the duration of 3


### statements of any witnesses. We don't have a big 4


### group today, so, hopefully, that will be a good 5


### opportunity for folks to speak. 6



### Each witness will be allowed to make an 7


### oral statement, which they may later expand on in 8


### writing for the record. 9


### I request that each speaker state their 10


### name and affiliation at the start, and when you 11


### are finished with your comments, the members of 12


### the panel, including myself, may ask clarifying 13


### questions. 14


### Let me emphasize this hearing is not 15


### intended to be a discussion of the proposed rule. 16


### While the folks up here might ask some questions 17


### or request some additional data or supporting 18


### materials based on your comments, we will not 19


### respond to comments in this forum. Instead, we 20


### will provide a written response to the relevant 21


### comments through the formal rulemaking process. 22

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### Specifically, if your comments are 1


### different today than your written comments, we 2


### ask that you please submit wr itten handouts 3


### directly to the docket. 4


### Comments that we will receive today, I 5


### will call folks up in a couple minutes today in 6


### the order that you were signed in. The speakers 7


### who registered first via the website and 8


### registration process will go first, fol lowed by 9


### speakers who registered here in person this 10


### morning. 11


### In looking at the list, I believe the 12


### first speaker today is Thomas Bach, representing 13



### the Interstate and Natural Gas Association of 14



### America. 15


### Mr. Bach, I'd like to invite you to the 16


### podium for your remarks. 17


### MR. BACH: Good morning. 18


### MR. GUNNING: Good morning. 19



### MR. BACH: I'm Thomas Bach. I am a 20



### Director of Environmental Services for Kinder 21


### Morgan. I am here today representing the 22

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### Interstate Natural Gas Association of America, 1



### otherwise know n as INGAA. 2



### INGAA is a trade association that 3


### advocates regulatory and legislative positions of 4


### importance to the natural gas pipeline industry 5



### in North America. INGAA ' s members, which operate 6


### approximately 200,000 miles of pipelines, 7



### represent the vast majority of the interstate 8


### natural gas transmission pipeline companies in 9


### the United States and comparable companies in 10



### Canada. 11


### Transmission pipelines are long

- line, 12


### high

- pressure pipelines, analogous to interstate 13


### highways. INGAA does not represent the gathering 14


### or distribution pipelines. 15


### We appreciate the EPA holding this publ ic 16


### hearing on the proposed rule, " Greenhouse Gas 17


### Reporting Program : 2015 Revision and 18


### Confidentiality Determinations for Petroleum and 19



### Natural Gas Systems. " 20


### First, let me say th at INGAA agrees that 21


### pipeline blowdowns can contribute to methane 22

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### emission levels. As a result, INGAA supports 1



### EPA ' s efforts to include pipeline blowdowns in 2


### its Subpart W reporting requirements for natural 3


### gas transmission pipelines. 4



### However, INGAA doe s has some concerns 5



### with the details of EPA ' s current proposal. In 6


### order to present a complete picture of the total 7


### methane emissions from the natural gas 8



### transmission sector and inform the cost

- benefit 9


### analysis for reducing those emissions, EPA should 10



### co nsider the current and future regulatory 11


### drivers for various emission categories, 12


### including pipeline segment blowdowns. 13


### Pipeline s egment b lowdowns are e ssential 14



### for s afe pipeline operation. Let me first 15



### descr ibe what a pipeline blowdown is in case 16



### people are not aware of it. A blowdown is the 17


### removal of product from the pipe in order to 18



### conduct maintenance. It is similar to how you 19



### would drain water from your hoses or exterior 20



### faucets before winter. 21


### Pipeline segment blowdowns are required 22

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### to perform ma intenance, testing, pipe 1



### replacements
, and for safe pipeline operations. 2


### The Pipeline and Hazardous Ma terials 3


### Safety Administration, hereinafter referred to as 4



### PHMSA , requires pipeline blowdowns as part of the 5


### replacement process for class location change s ; 6



### that is
, pipeline increases in the vicinity of 7


### the pipe line above specified thresholds and for 8


### hydrostatic testing for integrity testing, which 9



### is when

-- hydrostatic testing is when an 10


### operator tests the pipe using water under high 11



### pressures. 12


### Pipeline blowdowns can also be required 13


### for other pipeline safety purposes such as 14


### repairing third

- party or other pipe damage. 15


### In some cases, but not all, the required 16


### pipeline segment blowdowns are unnecessary since 17



### there are new advanced technologies such as 18



### im proved in

- line inspection technologies that 19


### exist to validate the pipe integrity without 20


### resulting in blowdowns. 21



### While pipeline blowdowns are not under 22

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### EPA 's jurisdiction, INGAA encourages the Obama 1



### a dministration to review existing and future 2


### pipeline sa fety regulations as part of a broader 3


### strategy for reducing methane emissions. The 4



### a dministration should consider allowing use of 5


### alternative technologies to ensure pipeline 6


### safety while reducing the requirements for 7


### pipeline blowdowns. Substantial metha ne emission 8


### reductions can be achieved by implementation of 9


### these alternative pipeline integrity 10


### technologies. 11


### With that said, p ipeline operators must 12


### have the ability and flexibility to blowdown 13


### pipeline segments to meet regulatory 14


### requirements, conduct pipeline maintenance and 15


### repairs, to maintain safe operations of this 16



### critical national infrastructure
, and to meet 17



### residential and industrial customer demands. 18



### In addition, INGAA encourages EPA to 19


### establish some de minimis reporting threshold for 20


### pipelin e blowdowns. 21



### I n terms of the specifics of the proposed 22

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### rule, I wil l briefly discuss concerns with, one, 1



### t he requirement for spatial location information 2



### for each blowdown event; two, t he effective date 3


### and timing of the rule; three, INGAA ' s support 4



### for ad vanced innovative monitoring methods. 5


### Pipeline blowdown spatial data. E PA 6


### proposes that pipeline blowdown data will be 7


### reported by the specific latitude and longitude 8



### where the blowdown occurs. 9



### However, operators currently do not 10


### compile pipeline blowdo wn data by latitude and 11


### longitude. Therefore, company management systems 12



### will need to be revised to address these new 13


### reporting requirements. There are significant 14


### implementation and timing costs associated with 15



### th o se efforts. 16



### In addition, EPA has not e xplained what 17


### the air quality benefit would derive nor why it 18


### said reporting at this level of detail is needed. 19


### INGAA recommends that pipeline blowdown 20



### data be reported by the pipeline operator, that 21


### is, the specific operating company, as EPA 22

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### currently pr oposes, but that it be done on a 1


### national or state aggregate basis. Reporting at 2


### the national or state aggregate basis would 3


### reduce implementation time and costs. 4



### Best Available Monitor ing Methods, 5



### otherwise known as BAMM. EPA proposes to allow 6



### operato rs to use preapproved BAMM from J anuary 1 7



### through March 31, 2016, to implement the systems 8


### necessary for the proposed reporting. 9



### INGAA believes that this is insufficient 10


### time for gas transmission and ot her affected 11



### sources, such as the gathering and oil p roduction 12



### operators, t o de velop and implement those 13


### systems. With that, INGAA recommends that EPA 14



### extend the BAMM deadline through 2016. 15


### Advanced innovative monitoring m ethods

. 16



### I NGAA supports EPA ' s proposal to allow use of 17


### advanced innovative monitoring technologies and 18



### methods. However, EPA will need to establish 19


### some type of verification and approval process 20


### for these technologies and methods. 21


### Pipeline operators should be given the 22

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### discretion to implement advanced innovative 1


### monitoring methods to rep lace existing Subpart W 2


### requirements rather than those methods being in 3



### addition to the current requirement s

. 4



### Other Comments. Other specific comments 5


### on the proposed rule will be included in INGAA ' s 6



### written comments. 7


### Finally, I NGAA appreciates the 8



### oppo rtunity to comment and looks forward to 9


### working with EPA and PHMSA to implement these 10


### proposed regulations in an efficient and cost

11



### effective manner and to continue to reduce 12


### unnecessary pipeline blowdowns

. 13



### Thank you. 14



### MR. GUNNING: Thank you, Mr. Bach, f or 15


### your comments. We appreciate that. 16


### Any clarifying questions? 17


### [No audible response.] 18



### MR. GUNNING: No? 19



### Thank you. 20


### MR. BACH: All right. Thanks very much. 21


### MR. GUNNING: Thank you. Appreciate it. 22

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### I think the next individual on our list 1



### is Karin Ritter from the American Petroleum 2



### Institute, but I believe Karin is not here at the 3



### moment. 4


### We will allow Karin an opportunity to 5


### work her way through the D.C. commute this 6


### morning and just take a short break for 15 7


### minutes, and we will resume, hopefull y, with 8



### Karin in the room. 9



### Thank you. 10



### [Break taken from 9:22 to 9:55 a.m.] 11



### MR. GUNNING: You are either frozen solid 12



### or very, very awake. 13


### At this point in time, it looks like our 14


### final registered speaker for the day has fought 15



### through the mayhem of D.C . traffic, Karin Ritter 16


### representing the American Petroleum Institute. 17


### Karin, I realized you just rushed into 18


### the room, but at your leisure, please approach 19


### the podium, and we welcome your remarks. Thank 20



### you. 21


### Yes, right here. 22

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### MS. RITTER: Oh, okay. V ery good. 1


### MR. GUNNING: The mic should be working 2



### too. 3


### MS. RITTER: All right. Okay. I have to 4



### get you all to look at. 5


### [Laughter.] 6


### MS. RITTER: I've been looking at people 7


### at a very close range for the last few minutes

-- 8


### or couple hours, and I think I am flying out from 9


### here up, so that's the important part as far as 10


### working. 11


### So, anyway, I'll indulge you for about 15 12


### minutes right now. First of all, good morning. 13


### I am Karin Ritter. I am the Manager with the 14


### Regulatory and Scientific Affairs Depar tment at 15


### API. API is the premier trade association in the 16


### petroleum and natural gas industry, with over 600 17


### member companies engaged in all aspects of the 18


### industry. 19


### Emissions have fallen drastically in 20


### recent years, thanks to industry leadership and 21



### inve stment in technology. Emissions will 22

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### continue to fall as operators innovate and find 1


### new ways to capture and deliver more methane to 2


### consumers. Existing EPA and state regulations 3


### are working, and another layer of burdensome 4


### requirements is unnecessary. The shale energy 5



### revolution has enhanced America's role as a 6


### global energy superpower, and the dramatic 7



### reductions in CO 2 

### emissions have been made 8


### possible by an abundant and affordable domestic 9



### supply of clean

- burning natural gas. 10


### API has a longstanding relationship and 11


### record of being a collaborative and cooperative 12


### stakeholder with EPA on implementing the 13


### Greenhouse Gas Reporting Program and shares EPA's 14


### goals of providing high

- quality data that takes 15


### into account the pragmatic operational and safety 16



### pr actices of our industry. 17


### Through the years, API has provided 18


### multiple sets of comments and technical 19


### information pertaining to the quantification and 20


### reporting of emissions under the reporting 21



### program. 22

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### EPA, in November 2015, finalized their 1



### 2014 revision s, and API and its members are still 2


### reviewing and assessing this recently promulgated 3


### rule and working to busily implement it under a 4


### very short time frame, mainly March 2015. 5



### At the same time, while that assessment 6


### of the 2014 promulgated revisions is o ngoing, API 7


### is providing our preliminary comments regarding 8


### these newly proposed requirements in the 2015 9



### revisions. 10



### API will submit a full set of written 11


### comments by the end of the comment period, which 12



### stands now at February 9th, or as requested by 13



### API in order to ensure a full and fair 14


### opportunity to provide constructive comments to 15



### EPA by March 9th. 16


### API and its member companies understand 17


### that in this proposed rule, which EPA initiated 18


### in response to requests by certain 19


### nongovernmental organizations, EPA proposes to 20


### amend Subpart W to require the reporting of 21


### greenhouse gas emissions from several sources 22

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### that are not currently included in Subpart W. 1



### However, API does not fully concur that 2


### all the revisions enhance the quality of the data 3



### from petroleu m and natural gas systems or would 4


### it lead to a better understanding of emission 5


### trends. Some of the new requirements are quite 6


### burdensome, overreaching, and do not even 7



### contribute to new emissions information. 8


### So, today, I will summarize our five 9


### major concerns. First, API is concerned that the 10


### newly proposed requirements pose an especially 11


### high burden on the industry sector. The EPA 12


### estimates that approximately 3,300 respondents 13


### will be subject to the regulation, and that this 14


### rulemaking will increase labor costs for 15


### Subpart W facilities by levying an incremental 16


### annual burden of 73,000 hours, valued at $7.2 17


### million per year, estimates which are 18


### extraordinarily slight compared to the real

- world 19


### experience of the industry. 20


### More specifically, the report ing burden 21


### estimated by EPA for the newly defined reporting 22

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### segment of Onshore Petroleum and Natural Gas 1


### Gathering and Boosting is grossly underestimated. 2


### Based on API's members' experience in reporting 3


### under Subpart W, this estimate is arbitrarily low 4



### by at least an order of magnitude, especially for 5


### the initial reporting year when one has to 6


### address the startup costs for setting up the 7


### reporting and recordkeeping systems for this 8


### newly defined segment. 9



### For the onshore petroleum and natural gas 10


### productio n segment, EPA states in its own 11


### assessment that the proposed reporting amendments 12


### would impose an additional annual burden of 13


### 57,963 technical hours for the production 14


### segment, which API contents is also 15



### underestimated. 16



### API maintains that EPA's estimate is 17


### highly unrealistic since it would mean that the 18


### increased annual burden for implementation of the 19


### new reporting requirements for the production 20



### segment would amount to only 29 hours per 21


### response, which is totally unrealistic, 22

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### especially in view of the e xtent of the new data 1


### collection and measurements required for 2


### implementation. 3


### So, for example, the inclusion of 4


### reporting requirements for blowdown vent stacks 5


### for the gathering and boosting segment will be 6


### quite burdensome for unmanned sites. The EPA 7



### T echnical Support Document justifies using 8


### default emission factors for quantifying fugitive 9


### emissions associated with the gathering and 10


### boosting segment, quote, because, as in the 11


### onshore petroleum and natural gas production 12


### segment, the equipment is often geographically 13


### dispersed and may be visited only 14


### intermittently," end of quote. 15



### For this same reason, EPA should exclude 16


### the reporting of emissions from blowdown vent 17


### stacks for gathering and boosting segment, 18


### similarly to its exclusion from the onshore 19


### petroleum and natural gas production segment. 20


### API urges the EPA to work with industry 21


### to streamline the reporting requirements in order 22

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### to minimize the heavy burden imposed on some of 1


### the petroleum and natural gas industry segments. 2



### Second, the rule prop oses to add 3


### requirements for reporting well identification 4


### numbers, which are claimed to improve data 5


### quality by enabling identification of wells 6



### associated with different sources. 7



### The EPA claims that these identification 8


### numbers are readily available and do not require 9


### any additional data gathering or calculation. 10


### API contends that this requirement is an 11


### overreach of EPA's authority for the reporting 12


### program, and the information requested is 13



### extraneous and not needed to validate emissions 14



### data. The requ irement is inconsistent with the 15


### aggregation of equipment and emissions within a 16



### basin or sub

- basin, as currently required in the 17



### rule. 18


### With the requirement for complete mapping 19



### of all wells to all sources, the EPA seems to be 20


### attempting to construct a co mprehensive 21


### accounting of wells and their ownership. 22

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### Therefore, such a requirement will impose 1


### significant implementation burdens without 2


### contributing to improved emissions data. 3



### API stresses that EPA's estimate that 4


### this requirement will impose only a s mall 5


### additional burden of 10 hours per reporter per 6



### year to report the well ID numbers lacks any 7


### rational basis and is arbitrary. 8


### In addition, EPA ignores the burden 9


### associated with mapping and maintaining the well 10



### ID database that could change throughou t the year 11


### due to the dynamics of well acquisition, 12


### divestment, and other changes to facilities 13


### operation and movement of transportable equipment 14


### based on operational needs. 15



### API also notes that EPA has other avenues 16


### at its disposal to acquire the well inf ormation 17


### data, such as commercial data systems like the 18



### DI

- Desktop or the EIA's information. 19


### API is requesting that EPA in the final 20


### rule abandon the requirement to provide a unique 21


### well identification number. This reporting 22

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### requirement does not have any influence on the 1


### final emission calculations and only serves to 2



### detract from the resources needed to manage and 3


### report the emissions data. 4


### Third, API appreciates the fact that EPA 5


### is citing API Recommended Practice 80 as a guide 6



### to the definition of the new reporting segment of 7


### onshore petroleum and natural gas gathering and 8


### boosting. 9


### API also supports the statement that this 10


### new reporting segment would not include equipment 11


### and pipelines that are reported under any other 12


### industry segment defined in Subp art W. In order 13



### to streamline the demarcation of boundaries and 14


### reporting obligations between the production and 15


### gathering/boosting segments, API offers two 16



### refinements. 17


### First, API requests that multiphase 18


### gathering pipelines be excluded from the 19


### gatheri ng/boosting segment and be retained as 20


### part of the production segment. 21


### Secondly, API requests that gathering and 22

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### boosting facility boundaries include dehydrators 1



### that are located on onshore petroleum and natural 2


### gas production well pads and operated by a 3


### gathering and boosting company. 4


### Moving these dehydrators into this newly 5


### created segment, rather than including them with 6


### the onshore petroleum and natural gas production 7


### segment will eliminate the concern of having 8


### producers report third

- party contracto rs' 9


### emissions, which the producers cannot certify. 10


### Fourth, EPA is proposing to add 11


### provisions for the reporting of greenhouse gas 12


### emissions from oil well completions and work

13


### overs with hydraulic fracturing, which are 14


### consistent with the current requireme nts for gas 15


### well completions and work

- overs with hydraulic 16


### fracturing. 17


### The proposed provision apply expanded 18


### measurement requirements to oil well completions 19


### with hydraulic fracturing that use flaring and 20


### reduced emission completions, or RECs. 21



### API notes that EPA assumes that operators 22

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### know in advance whether a completion or work

- over 1


### will require flaring. In reality, it is not 2


### possible to determine whether a well will clean 3


### up quickly with no need to flare or vent prior to 4


### beginning the actual flow

- back. Therefore, 5


### flaring versus venting cannot be the deciding 6


### criteria for planning which wells to measure or 7



### collect information to enable the calculation of 8



### the flow

- back volume. 9



### Besides the obvious cost and burden 10


### implications of quadrupling the number of 11


### possible combinations requiring measurement or 12


### calculation in each county, this will be a 13


### scheduling impossibility for operators. 14


### API is requesting that upon promulgation, 15


### EPA establish only two categories for reporting 16


### emissions from completions and wor k

- overs with 17


### hydraulic fracturing, namely venting without REC 18


### and vented with REC and flaring. 19


### Fifth, and finally, in the preamble to 20


### the proposed rule, the EPA discusses the 21


### potential opportunities for applying remote 22

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### sensing technologies and other innov ations in 1


### measurement or monitoring technology to identify 2



### and calculate emissions from affected sources 3



### under Subpart W. 4


### EPA's stated objectives are to determine 5


### if new and innovative technologies could be 6


### applied to the reporting program to improve the 7



### overall accuracy of transparency of reported data 8



### in a cost

- effective way. 9


### API views the introduction of this topic 10


### as totally inappropriate within the framework of 11


### the proposed revisions, which are intended to 12


### address the introduction of new reporting 13



### re quirements for new segments and selected 14


### operations. The issue of using advanced 15


### monitoring techniques is pertinent to all the 16


### sectors that are subject to part 98 and its 17


### various subparts and should not be constrained 18


### just within the Subpart W framework. 19



### API requests that EPA acknowledge upon 20


### promulgation that this discussion is premature 21



### for consideration under this rule and should 22

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### defer the request for comments and information on 1


### the topic until after all the new 2015 reporting 2


### requirements are implemen ted. 3


### So, in summary, API respectfully requests 4



### that EPA consider that API's members, if not all 5


### of industry, are still in the process of 6


### implementing the promulgated 2014 revisions as 7


### part of their annual reporting obligations along 8


### with preparing to repo rt the previously deferred 9


### data elements by March 31st of this year. 10



### EPA should allow for sufficient time to 11


### review and comment on the multiple new 12


### requirements in this proposed rule and should 13


### defer the comments submittal date by at least 30 14



### days, as API has already requested to March 9th, 15


### or preferably until after March 31st when the 16



### annual reports are due. 17


### EPA is greatly concerned by the burden 18


### imposed by the EPA on the petroleum and natural 19


### gas industry with back

- to

- back promulgation of 20



### the 2014 revis ions and the proposal of reporting 21


### expansion in the 2015 revisions. 22

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### Therefore, API requests that EPA extend 1


### the public review period to provide adequate o pp 2


### for public comments. 3


### We look forward to continuing our 4


### constructive and established relationship with 5


### EPA in pursuit of our shared goal of providing 6


### high

- quality data that can be reported in a way 7


### that reflects the pragmatic realities of our 8


### industry. 9


### Thank you. Appreciate it. 10


### MR. GUNNING: Thank you, Karin. 11


### Any clarifying comments from

-- 12



### MS. M cKITTRICK: No. 13



### MS. KARIMJEE: No. 14



### MR. GUNNING: No? 15



### Thank you so much for your remarks. 16



### MS. RITTER: Okay, great. 17


### MR. GUNNING: We appreciate it. If they 18


### are different, Karen, than from what you plan to 19


### submit in writing, please submit those to the

-- 20



### MS. RITTER: I will submit these. I 21



### brought along a copy. 22

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### MR. GUNNING: Okay. Thank you so much. 1



### Thank you so much. 2



### That concludes, I believe, unless there 3


### are other registered speakers, which I don't 4


### think that there are, our cold hearing for thi s 5


### morning. I'd like to thank everyone for their 6


### time and specifically for INGAA and for API for 7


### offering their comments this morning, and stay 8



### warm, everyone. Take care. 9


### [Whereupon, at 10:12 a.m., the public 10


### hearing concluded.] 11

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