Texas Pipeline Association

Thure Cannon

President

June 16, 2014

Submitted to oilandgas.whitepapers@epa.gov

Environmental Protection Agency

1200 Pennsylvania Avenue, NW

Washington, D.C. 20460

Re: Technical White Papers on Potentially Significant Sources of Emissions in the Oil

and Gas Sector

Dear Sir or Madam:

The Texas Pipeline Association ("TPA") submits the following comments on the White

Papers released by EPA on April 15, 2014 concerning methane and volatile organic compound

("VOC") emissions from leaks, compressors, and pneumatic devices in the oil and natural gas

sector (hereinafter referred to as "the White Papers"). TPA is an organization composed of 48

members who gather, process, treat, and transport natural gas and hazardous liquids materials

through intrastate pipelines in Texas. TPA members own and operate facilities that are the

subject of methane controls discussed in the White Papers. Accordingly, TPA members will be

impacted by any policy choices made by EPA that might follow finalization of the White Paper

process.

TPA recognizes that EPA is currently subjecting the White Papers to a peer review

process and has also provided an opportunity for persons to file comments on the White Papers

in general. Any concrete regulatory or policy proposals would be developed by EPA only after

the White Paper peer review process is complete. However, TPA believes that it is important to

share its general comments on the White Papers at this early stage. While TPA has not been able

to conduct a comprehensive review of the proposals contained in the White Papers nor a

comprehensive review of the studies relied upon in the White Papers, it does offer general

overarching comments on the White Papers here followed by specific comments on three of the

five White Papers that directly pertain to TPA members' operations: leaks, compressors, and

pneumatic devices. In addition, TPA endorses and supports the comments of American

Petroleum Institute ("API") and the Interstate Natural Gas Association of America ("INGAA").

1. Natural gas is a key component of a strategy to address the impacts of climate

change, and as such EPA should encourage voluntary actions rather than

promulgating new prescriptive regulations

604 West 14th Street, Austin, Texas 78701

phone: (512)478-2871 fax:(512)473-8476 Email: thure.cannon@texaspipelines.com
The White Papers are a part of the Obama Administration's strategy to reduce methane

emissions, which is aimed at taking action on the effects of climate change by reducing methane

emissions from landfills, coal mines, agriculture sources, and sources in the oil and gas industry.1

Inasmuch as the White Papers were issued as a step in the Administration's effort to address

climate change, at the outset, TPA wishes to emphasize that the natural gas industry, and the use

of clean burning natural gas, is a crucial component in the strategy to combat climate change.

Natural gas is a cleaner burning fuel compared to other fuel sources. Increased use of natural

gas, for example by electricity generators, has led to reductions in domestic greenhouse gas

("GHG") emissions in the recent decade.2 Additional GHG emission reductions will be achieved

as natural gas usage increases in other sectors of the economy, such as transportation and

manufacturing. Moreover, the natural gas industry has itself achieved significant reductions in

methane emissions over the last two decades; specifically, natural gas system methane emissions

have decreased almost 17% from 1990 to 2012,3 even as natural gas production, processing, and

transmission have significantly increased during the same time period.

This progress has been the result of voluntary efforts, not federal regulations. Operators

have both an economic and a safety incentive to reduce losses of natural gas in the processing,

transmission, and delivery sectors. Thus it is unnecessary to institute a new regulatory program

that would prescribe methods to curb leaks or other losses; operators are already implementing

voluntary methods to reduce leaks and emissions, and these efforts have been successful because

operators are free to implement whatever methods are best suited to their own particular

facilities. Instead EPA should look to voluntary or cooperative programs that achieve the same

end result. In this regard we would also point to find-and-fix initiatives that have been used in

the past by the Texas Commission on Environmental Quality ("TCEQ") as an example of an

effort that effectively reduced emissions through cooperative efforts between government and

private industry. When TCEQ fly-overs detected high emissions levels in a given area, TCEQ

has contacted the operators that could be responsible for the emissions so that the operators can

make any necessary corrections to stop the emissions. In one instance, such an effort in the

Houston Ship Channel resulted in reductions of VOC emissions of 7,000 tons per year.

Any prescriptive regulations in this area would both reduce operators' flexibility and

would undoubtedly have the ancillary effect of raising operational costs, thus contributing to a

rise in natural gas prices. One of the main reasons why use of natural gas is increasing is that it is

a relatively inexpensive domestic resource. Use of natural gas as a fuel results in lower GHG

emissions upon combustion relative to other fuel choices. As such, it would be unfortunate if

"Climate Action Plan, Strategy to Reduce Methane Emissions," March 2014, available at

http://www.whitehouse.gov/sites/default/files/strategy to_reduce_methane_emissionsj2014-03-

28_fmal.pdf.

2 See, e.g., "Leveraging Natural Gas to Reduce Greenhouse Gas Emissions," Center for Climate and

Energy Solutions, June 2013 at 1, 20, available at http://www.c2es.org/docUploads/leveraging-naturalgas-reduce-ghg-emissions.pdf.

3 See "Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2012," EPA 430-R-14-003 (April

15, 2014), Executive Summary at ES-13-14, available at

http://www.epa. gov/climatechange/ghgemissi ons/usin ventorvreport.html.
EPA's promulgation of new regulations unduly burdened the natural gas industry and resulted in

higher prices for natural gas, thus reducing the economic incentives to use natural gas that

currently exist. EPA should encourage industry participants to engage in voluntary / cooperative

actions to reduce methane and VOC emissions, rather than promulgating new regulations that

would prescribe costly reductions and the methods that would be required to achieve them.

2. The White Papers contain various flaws and inconsistencies that limit their

usefulness as a source of information upon which the consideration of methane

reduction regulations may be based.

We note that EPA has characterized the White Paper review process as a major step in

the development of strategies to reduce methane emissions. EPA has indicated that it intends to

use the information contained in the White Papers, and the underlying studies to which the White

Papers refer, to inform its actions going forward, which actions could include the promulgation

of new regulations.

TPA urges EPA to work with industry before the agency takes any steps in response to

the findings reported in the White Papers. We deem it to be crucial that, prior to the

consideration of any future policy choices such as the possible promulgation of new regulations,

EPA obtain a full and complete understanding both of operational processes in the oil and gas

industry and of potential costs or logistical issues that might be caused by new regulations.

Actively engaging knowledgeable stakeholders such as industry representatives in the

development of any potential approaches to encouraging voluntary reductions of methane

emissions, or the promulgation of new rules, will increase the probability that such new policies

will be targeted and narrowly focused; as opposed to polices that are broad and unduly

burdensome.

Our emphasis on the need for continued active industry participation in the consideration

of any future policy choices that EPA might make is based in part on our review of the White

Papers here at issue. EPA has indicated that the content of the White Papers will be important in

informing future EPA efforts to reduce methane emissions, yet we believe that the White Papers

suffer from some overarching flaws that substantially reduce their effectiveness and usefulness

as an informational tool. Our general concerns regarding the White Papers are discussed below.

a. It is difficult or impossible to draw accurate conclusions from information

presented in the White Papers, due to inconsistencies that exist from one

report to the next.

First, it is very difficult to follow the White Papers' discussion of the various studies

being referenced. There is no conversion of the measurements and calculations in the studies,

meaning that "apples to apples" comparisons from one report to the next are not possible.

Emissions calculations are stated in varying measurements, e.g., Mscf/yr, MT/yr,

scf7day/compressor, tons/compressor/year, scfy/device, or scfy/plant, to name a few; this makes

it very difficult to draw a consistent comparative picture of emissions or potential emissions

reductions from study to study. Moreover, the measurements themselves are calculated in
various ways, e.g. some by direct measurement, some by use of emission factors, and some by

the use of Best Available Monitoring Methods ("BAMM").

The ability to compare results from one report to the next is further complicated by the

fact that it is not always clear what sort of components comprise the various categorical

groupings, i.e. production, processing, transmission, storage, and distribution. An example of

this is the categorization of gathering and boosting facilities: on occasion it is not clear whether

such facilities are grouped within the statistics for production or for processing. Uncertainties

such as these make it hard to use the results of the referenced reports in any meaningful way.

Yet another issue in this regard is that the universe of facilities being examined varies

widely from study to study. Some studies purport to calculate results, e.g. methane emissions,

from all domestic sources, while others (e.g. the mandatory GHG reporting program results) only

capture information from sources meeting the program's tons per year reporting threshold. Still

other reports were extremely localized in nature, such as the URS/University of Texas report on

compressor methane emission factors, which measured only 11 facilities in Texas and New

Mexico, or the Marcellus Shale pneumatic device emissions report, which focused only on a

single shale play. Localized studies such as these may be of limited use in understanding

operations in other parts of the country, where operating conditions may be fundamentally

different.

At a minimum, EPA should reconcile and harmonize the figures and estimates set forth in

the various studies before the agency draws any conclusions about emissions levels, appropriate

emissions reduction strategies, and costs associated with implementation of such strategies.

Until this is done, it will be very difficult for the agency or third parties to understand the

nuances in the underlying information presented in the various studies reviewed in the White

Papers and to determine appropriate regulatory or policy responses to the data.

b. The White Papers omitted the inclusion of relevant and current emissions

studies that would further inform its decision making process.

The White Papers summarize some, but by no means all, of the current studies

concerning methane emissions and potential reduction measures in the oil and gas industry. TPA

is not aware of the criteria utilized by EPA in the selection of some relevant air emissions studies

or reports but not others. We request that EPA provide an explanation as to why it chose to

review certain reports and exclude others. We urge EPA to refrain from placing undue weight

on the limited information now set forth in the various White Papers, as they represent a partial

but not a complete view of available information, and other extant reports may draw different

conclusions on the same subject matter.

For example, the White Papers fail to reference pertinent sources of information

regarding cost-effective methods of reducing methane emissions. This topic has been reviewed

by the International Petroleum Industry Environmental Conservation Association4 and the

4 See "Oil and Natural Gas Industry Guidelines for Greenhouse Gas Reduction Projects," (March 2007),

available at http://www.ipieca.org/publication/oil-aiid-natural-gas-industry-guidelines-greenhouse-gasreduction-proiects.
Intergovernmental Panel on Climate Change,5 among others, yet no mention of these reviews is

made in the White Papers. Similarly, the White Papers do not take into account the ongoing

series of methane reports being produced by the Environmental Defense Fund in collaboration

with representatives from the oil and gas industry and academia; this effort has already resulted

in reports on methane emissions during production of natural gas and on methane emissions in

Colorado, and future reports will address the extent of methane emissions in other parts of the

natural gas supply chain, including the transmission, storage, gathering, and processing

segments of the industry.

Another report that EPA fails to reference is a recent study by Eastern Research Group

("ERG") which developed county- and region-specific emission factors for estimating

condensate storage tank emissions for different areas in Texas. The ERG report corrected an

inaccurate 33.3 Ibs VOC/bbl emission factor for condensate storage tanks that had been used by

TCEQ, which in turn was derived from a 2006 study prepared by URS Corporation for the

Houston Advance Research Center ("HARC"). The URS / HARC study was widely considered

to be erroneous, and the 33.3 Ibs VOC/bbl emission factor was viewed as being far too

conservative and thus too high. Responding to widespread criticism of the 33.3 Ibs VOC/bbl

emission factor, TCEQ contracted with ERG to conduct a new study on condensate storage tank

emissions for different regions in Texas. ERG analyzed an extensive amount of information,

much of which had become available since the URS / HARC report was issued, including

TCEQ's Barnett Shale Phase II Special Inventory data; available literature containing data on

emissions testing and emissions estimates for condensate tanks in Texas; the results of phone

surveys of Texas condensate producers; and additional data on emissions estimates obtained

from several recent studies evaluating condensate storage tank emissions. TCEQ published the

ERG report on October 24, 2012,6 and among the report's conclusions was that the appropriate

Production Weighted Emission Factors for use in Texas were substantially lower than the 33.3

Ibs VOC/bbl factor contained in the URS / HARC report. This report is important in assessing

VOC emissions from storage tanks and as such it should be considered by EPA before the

agency makes any additional policy choices related to reduction of VOC emissions from storage

tanks.

We urge EPA to conduct a comprehensive review and analysis of all pertinent studies in

the White Paper process before the agency makes any future policy choices related to reducing

methane or VOC emissions. Only if this is done will EPA and the regulated community have

before it the most up-to-date and current analysis of emissions, and potential emission reduction

opportunities, present in the oil and gas industry.

c. The White Papers fail to consistently recognize that recovered product due to

methane emission reductions do not always benefit the owner of the site, nor

5 See "Climate Change 2007," Fourth Assessment Report (AR4) of the United Nations Intergovernmental

Panel on Climate Change, Synthesis Report, available at http://www.ipcc.ch/pdf/assessmentreport/ar4/syr/ar4 svr.pdf.

6 The ERG report is available at

https://www.tceq.texas.gov/assets/public/implementation/air/sip/ozone/pAppB AreaSourceCondensateTa

nkpdf.
do they take into account all relevant costs associated with steps to reduce

emissions.

Another overarching concern is that the White Papers' discussion of potential economic

benefit that a site operator may realize by reducing emissions should always take into account

the potential that the site operator may not own the natural gas throughput. When this is the

case, the site operator does not stand to realize an economic benefit through emissions

reductions. We note that the White Papers do take this into account on at least one occasion,7 but

this is an important factor that EPA should always take into account when assessing a site

operator's potential savings through emission reductions: if an operator does not own the gas, it

will not receive the corresponding benefit of the value of recovered product.

In addition, TPA is concerned that the White Papers do not accurately reflect all of the

costs associated with equipment maintenance, repair, and replacement. At various points the

White Papers set forth monetary amounts purportedly representing operators' costs to take steps

to reduce emissions, e.g. replacing wet seals with dry seals on centrifugal compressors, replacing

rod packing on reciprocating compressors, or replacing high-bleed pneumatic controllers with

low-bleed controllers. But it does not appear that the costs associated with such steps are fully

accounted for in the White Papers, because for example the costs associated with equipment

downtime are not included. In short, equipment or labor expenses are certainly a part of the

cost associated with implementing the steps suggested by EPA in the White Papers, but the costs

by no means end there. Any realistic assessment of the overall costs associated with taking steps

to reduce emissions should be assessed by EPA in conjunction with industry stakeholders so that

there is an accurate accounting of all relevant costs.

d. EPA should remain open to comments on the White Papers and revise them

before basing any final policy decisions on them.

In summary, we believe that issues such as those set forth above limit the usefulness of

the White Papers, as currently drafted, as a source of information upon which to base any future

policy decisions, such as the promulgation of new methane reduction regulations. Accordingly,

we would caution against over-reliance on the current drafts of the White Papers. We would

urge EPA to remain open to revisions and additions to their content before any final policies are

developed. Once again we would strongly recommend that EPA engage in close communication

with industry representatives in the course of any agency policy or rulemaking initiatives, so that

industry processes and potential economic impact of new regulations, are fully understood by the

agency. In addition, we would urge EPA to finalize its data collection through the

comprehensive GHG reporting rule program, i.e. Subpart W, before considering whether

additional regulations aimed at reducing methane emissions from the oil and gas industry are

necessary.

3. TPA's comments on the individual White Papers.

7 See "Oil and Natural Gas Sector Compressors," Report for Oil and Natural Gas Sector Compressors

Review Panel, April 2014, at 38.
TPA's ability to fully analyze the White Papers was hindered by the short amount of time

provided for the filing of comments. A complete analysis would have necessitated an in-depth

review not just of the White Papers themselves but each and every report referenced in the White

Papers - tasks that would have required far more time than was available to reviewers given

EPA's adherence to its June 16, 2014 comment deadline.8 Accordingly, TPA's responses to the

individual White Papers will be limited to those areas of particular concern to TPA, and we

adopt and incorporate the comments filed by the API and INGAA.

a. Leaks.

The White Paper addressing leaks incorrectly assumes that it is always in the operator's

economic interest to repair a leak as soon as it is discovered. EPA fails to consider the fact that,

in a given circumstance, a facility may have to shut down operations so that a leak repair can be

accomplished. The downtime associated with leak repair results in lost economic opportunity,

which may outweigh any economic benefit gained by repairing the leak. Similarly, in a given

situation the cost of repair may far outweigh the value of the gas being emitted. EPA itself has

acknowledged that it makes economic sense to repair some leaks but not others; this recognition

is one of the bases of a Directed Inspection and Maintenance ("DI&M") approach to leak repairs

at compressor stations, which EPA has characterized as a "proven, cost-effective way to detect,

measure, prioritize, and repair equipment leaks to reduce methane emissions."9 As EPA has

noted:

Leak measurements ... must be evaluated to pinpoint the leaking components that

are cost-effective to repair. Leaks are prioritized by comparing the value of the

natural gas lost with the estimated cost in parts, labor, and equipment downtime to

fix the leak. Some leaks can be fixed on the spot by simply tightening a

connection. Other repairs are more complicated and require equipment downtime

or new parts. For these repairs, operators may choose to attach identification

markers, so that the leaks can be fixed later if the repair costs are warranted.10

Thus, while some facility operators have an economic incentive to prevent loss of natural gas,

EPA's discussion of the economic incentives for operators to repair leaks, and its discussion of

the costs involved, should not assume that it is always in an operator's economic interest to

immediately repair leaks when they are detected. In addition, in some instances repairing a leak

can result in more emissions than the leak itself; in this regard we note that in one TCEQ

regulation when a repair of a leak would generate more emissions than the leak at issue, the

8 By letter dated May 15, 2014, TPA requested an extension of time for the filing of these comments,

noting that each of the White Papers raised numerous issues that would require commenters to undertake

a detailed analysis and present detailed economic and technical responses to address the issues raised.

EPA did not grant that request.

9 "Directed Inspection and Maintenance at Compressor Stations," Lessons Learned from Natural Gas

STAR Partners, EPA 430-B-03-008 (October 2003) at 1, available at

http://epa.gov/gasstar/documcnts/ll dimcompstat.pdf.

10 Id. at 5; see also id. at 1, 4-5 (one of the steps in the DI&M approach is identifying candidates for costeffective repair).
repair may be delayed until the next scheduled shutdown.11 Accordingly, EPA's assessment of

the economic or environmental benefits of leak repair should bear in mind not only that it may

not be economically advantageous to immediately repair every leak that is found, but also that it

may be more beneficial to the environment in a given circumstance if leak repair is delayed until

such time as the repair can be accomplished without an unnecessary increase in emissions.

Another flaw in the White Papers' assessment of the economic benefits of stopping leaks

is the fact that the value of leaked natural gas is often unrealistically inflated in the cited reports.

It is common knowledge that the price of natural gas has significantly decreased in recent years,

yet these price decreases are not always reflected in the cited reports which purport to show the

value to the operator in repairing leaks. Studies putting the value of saved natural gas at figures

such as $7.15/Mcf12 are unrealistic and do not reflect current natural gas prices. As a result, such

studies overestimate the economic value of leak repair.

TPA also disagrees with the White Paper's inclusion of "ambient/mobile monitoring" as

an available method of leak detection. As an example of such technology, EPA discusses the

agency's Geospatial Measurement of Air Pollution ("GMAP") program.13 Such technology is

not a useful took in leak detection because it does not identify the specific source of the leak, i.e.

the leaking component. Rather, it merely identifies atmospheric methane and estimate emissions

that may be attributable to an upwind source or sources. Because multiple oil and gas sites are

often located close to one another, the ambient/mobile monitoring technology may detect

emissions from multiple sites, even those owned by different companies. This is the opposite of

the precision that is often required in proper leak detection. Effective leak detection technology

enables an operator to identify the source of the leak, e.g. an infrared camera or audio, visual,

and olfactory ("AVO") methods. Ambient/mobile monitoring does not fulfill the requirement to

identify the leak source and as such it should not be identified as a leak detection technology.

Finally, TPA urges EPA to refrain from promulgating any regulations that would require

operators to utilize traditional leak detection and repair ("LDAR") methods, including the use of

Method 21, to detect leaks at their facilities. The use of LDAR is not always necessary or cost

effective. Indeed, EPA itself notes that "typically 20% of the top leaking components account

for approximately 80% of the emissions from a facility."1 EPA's focus should be on the

detection and repair of this group of large leaks, and such large leaks can be detected by the use

11 See 30 Tex. Admin. Code § 106.352(e)(5)(B) (providing that "[ajll components found to be leaking

shall be repaired. Every reasonable effort shall be made to repair a leaking component. All leaks not

repaired immediately shall be tagged or noted in a log. At manned sites, leaks shall be repaired no later

than 30 days after the leak is found. At unmanned sites, leaks shall be repaired no later than 60 days after

the leak is found. If the repair of a component would require a unit shutdown, which would create more

emissions than the repair would eliminate, the repair may be delayed until the next shutdown."). TPA

urges EPA to ensure that a similar, common-sense approach is incorporated into any regulations that the

agency may promulgate in the future.

12 See "Oil and Natural Gas Sector Leaks," Report for Oil and Natural Gas Sector Leaks Review Panel,

April 2014, at 48.

13 Id. at 45.

14 Id. at 50.
of AVO methods or FLIR cameras, without the need for the pinpoint detection provided by

traditional LDAR / Method 21. AVO has been proven to be an effective method of leak

detection in the oil and gas industry; inspectors and operators consistently detect leaks using this

method on a daily basis. It is more cost effective, requires less specialized training and no

equipment, and it can be conducted by individuals that are already onsite for daily duties. There

is no need for mandated use of traditional LDAR / Method 21.

b. Compressors.

TPA is concerned with EPA's conclusions regarding the efficacy of vapor recovery unit

("VRU") systems to control emissions. Specifically, the White Paper states that emissions can be

captured from reciprocating compressor rod packing vents by manifolding the vent line to a

VRU system.15 While this may be true in some cases, the White Paper fails to acknowledge that

use of a VRU to capture emissions is not always feasible.

For example, the use of a VRU system presents safety and operational issues that must be

considered. The influx of oxygen associated with a VRU can pose the risk of explosion and can

cause pipeline corrosion. In addition, if a VRU system were used on rod packing vent lines,

there is the possibility that a malfunction could occur that would cause negative pressure to

misdirect the natural gas back toward the rod packing, thus cause the area surrounding the

compressor to be engulfed in natural gas and creating a fire hazard.

The use of a VRU system would also have the effect of increasing emissions in some

cases. For example, if a VRU were used to capture rod packing emissions, the operator would

have to install a compressor to compress the leakage to the pressure rate necessary to pipe it to

the VRU, resulting in additional emissions. Further, engine oils and lubricants must be removed

before they reach the compressor associated with the VRU system because they would damage

the compressor equipment if they reached the compressor. Accordingly, controls would have to

be installed that would shut the system down if liquid were detected in the line. Any subsequent

blowdown of the systems that had been shut down would result in the release of additional

emissions to the atmosphere.

In short, TPA does not believe that the White Papers have sufficiently considered the

safety, operational, or environmental issues associated with attempting to transfer the technology

of vapor recovery for use on rod packing vent lines.

c. Pneumatic devices.

In addition to the comments submitted by API and INGAA regarding EPA's White Paper

on pneumatic devices, TPA believes that it is important to emphasize the impracticability of the

White Papers' suggestion that operators convert to pneumatic devices driven by compressed air

or to solar-powered systems. Both of these purported alternatives present significant reliability

issues.

5 See "Oil and Natural Gas Sector Compressors," Report for Oil and Natural Gas Sector Compressors

Review Panel, April 2014, at 34-35.
The use of compressed air requires the installation of equipment to compress and control

the pressured air. A key component of a compressed air system is an electric compressor,

meaning that reliable electricity is essential to the proper continuous functioning of the system.

The problem is that operators, particularly those in remote areas, do not always have access to

consistently reliable electric power. Electricity outages are not uncommon, especially in rural

areas where electricity may be supplied by rural electric cooperatives whose systems may be

particularly susceptible to outages. Of course, back-up systems can be implemented, but such

systems (e.g. powered by diesel fuel) will supply power for only a limited period of time, after

which the absence of electricity will force the operator to shut the system down. This, in turn,

can result in a blowdown, which ironically results in increased methane emissions. The same

unreliability concerns apply to solar-powered systems. Solar power can be an effective source of

energy in certain limited situations, but by its very nature it is not a continuous power source and

thus is inherently unreliable.

TPA appreciates the fact that alternative sources of energy may be available in certain

circumstances, and where this is the case, the feasibility of taking advantage of such alternative

sources is worth exploring. But in no event should reliability be sacrificed, because without

continuous power the production and transmission of natural gas cannot take place.

Accordingly, EPA should not assume that switching to instrument air or solar power is anything

more than a possible alternative that may, in certain cases, be a viable option to an operator. In

no event should the use of such alternatives be mandated.

4. TPA endorses and adopts the comments submitted by API and INGAA.

As noted above, these comments address some but not all of TPA's concerns regarding

EPA's methane White Papers. Many of TPA's concerns are addressed in the comments filed by

API and INGAA, TPA expressly adopts and endorses those comments as if fully stated herein.

We appreciate the opportunity to submit these comments.

Yours ti

Thure Cannon

President

10