DEPA is... The Domestic Energy Producers Alliance (DEPA), Inc., is anationwide collaboration

of oil and natural gas organizations, including state, regional and national groups.DEPA and its 15 coalition associations represent approximately 10,000 individuals and companies engaged in the domestic on-shore crude oil and natural gas exploration and production (E&P) sector. This organization represents

a majority
of the individuals and companies responsible for the current renaissance

in American oil and natural gas production. In its fifth yearof existence, DEPA is comprised
of independent oil and gas producers who drill morethan 90 percent of the newoil and gaswells in the United States each year.DEPA membership also includes oilfield service companies and royalty owners. Comments
on Oil_and Gas NSPS Regulations The New Source Performance Standard modifications are published under the authority
of Section 111(b) (1) (B) of the Clean Air Act (“CAA”),
42 U.S.C.

§ 7411(11) (1) (B), “to review and revise the [new source performance standards (“NSPS”)] for the Crude Oil and Natural Gas Production source category. These regulatory modifications

to the Quad

0 regulations were developed

asaresult of the consent decree in the court action of plaintiffs Wild Earth Guardians and San Error!Unknown (Jocumenipropertyname.Juan Citizens Alliance

vdefendant Lisa P. Jackson, Administrator, U.S. Environmental Protection Agency (“EPA”).In effect this consent decree directed that ‘No later than January 31, 2011, the appropriate EPA official shall sign oneoracombination

of the following for the NSPS Subparts KIcK and LLL: (a)
a proposed rule containing revisions

tothe NSPS [(in whole orin part) under CA] section 111(b) (1) (B)]; (b)
a proposed determination
notto revise the NSPS [(in whole orin part) under CAA section 111(b) (1) (13);] and/or (c)
a proposed
orfinal determination
not to review the NSPS [(in whole orin part) under CA.A section 111(b) (1) (B)]. The EPA chose toreview and revise the NSPS regulations, but owing tothe time constraints placed uponthem in the consent decree, these revisions were developed
in arushed and haphazard fashion.
In fact, these rules hold the record for the longest time lapsed from the signing by the administrator

to final publication

in the Federal Register. DEPA is concerned about the resourcesthat are required to comply with

arule that was developed
in this manner.DEPA’s members believe Quad

0 imposes

a Error!tnkiiowiidocilmentpropertymrn•significant regulatory burden with questionable environmental benefits. This burden falls disproportionately

on independent producers. Because domestic O&G production

is fueled primarily
by our country’s independent producers, regulations like Quad o pose

a potentially, gravethreat to the questfor American energy independence. DEPA’s members are fully supportive

of measures designed
to protect the environment. Many of our members arealso farmers and ranchers and assuch represent the true environmentalists

of our country. But our country cannot continue
to develop and impose regulatory burdens on industry that require vast expenditures but that do not render anyreal and measurable benefit
to the environment. The EPA’s Regulatory Impact Analysis provides
noscientific basis for this rule and fails to quantify the asserted environmental
and public health benefits
to be derived from the claimed reduction
in VOC emissions. The costs of the rule—properly estimated--far outweigh any hypothetical benefits. When EPA does not take the time to understand the industry
it seeks to regulate and the problem
it seeks to remedy, the agencycannot hope to promulgate intelligent and meaningful regulations. And by hastily publishing poorly researched regulations Error!Unknowndocumentpropertyname.like Quad 0, EPA inflicts disproportionate
and unnecessaryharm onAmerica’s independent producers. Despite DEPA’s objections

to Quad 0, its members are doing their best to comply with the rule’s requirements (even asEPA has goneback tothe drawing board to correctthe hastily published first version of the rule).However, DEPA members’ efforts
to comply with Quad

0 have been complicated

by confusion within state regulatory agencies.

In the absence of meaningful state guidance regarding this rule’s applicability, regulatory uncertainty within the states will continue to translate into regulatory uncertainty for DEPA’s members. In short, we urgethe EPA to exercise greater caution and discretion when promulgating
anyenvironmental regulations,

I order toensurethat the remedy does in fact effect

acure; especially when the costof the remedies aresodear asthose associated with the modified NSPS rule. DEPA appreciates the opportunity

to appearhere today and looks forward
to providing further input toEPA on its concernsabout the Quad

0 rule and its implementation. Thank you. Erro,!

I‘nknown(lorument propcrt3name.