-----Forwarded by Melanie King/RTP/USEPA/US on 05/14/2010 06:41PM -----
To: Melanie King/RTP/USEPA/US@EPA 
From: "Matt Todd" <ToddM@api.org> 
Date: 05/14/2010 06:13PM 
cc: RobertJ Wayland/RTP/USEPA/US@EPA 
Subject: UA/UC White Paper
Melanie,

The attached “white paper” supports the use of the Urbanized Area and Urban Cluster Census 
2000 approach for defining urban areas.  This is consistent with the approach used to identify 
sources as rural or urban in 40 CFR 63 Subpart HH (ONG NESHAP).  The Census Bureau 
evolution of the urban / rural classification scheme has exploited Geographic Information System 
(GIS) technology and leveraged population data to improve and refine definitions over time.  As 
we discussed during our meeting, relying on the outdated 1990 Census classification scheme and 
urban-1 / urban-2 definitions would classify many counties in oil and natural gas production 
locations like Wyoming as “urban”, which is an inappropriate determination based on a common 
understanding of these terms.

API does not believe that EPA is limited to the narrow and outdated definitions of U1 and U2 
from the 1990 Census approach referenced in the Urban Air Toxics Strategy (UATS), instead the 
UATS recognized that urban areas would evolve by proposing that “the area in which standards 
will apply should be made separately for each source category.”  The UATS simply relied upon 
the common contemporary Census Bureau definitions, and there is no compelling reason to 
ignore subsequent improvements in the knowledge base.

On a related note, API would like to reiterate concerns expressed in our original comments 
regarding treatment of oil and gas operations under §CAA112(n)(4)(B).  API comment 2.1 (page 
11 of 100) requested that EPA consider proximity to urban areas.  

CAA §112(n)(4)(B) states:
The Administrator shall not list oil and gas production  wells (with its associated 
equipment) as an area source category  under subsection (c) of this section, except that 
the  Administrator may establish an area source category for oil and  gas production wells 
located in any metropolitan statistical area  or consolidated metropolitan statistical area 
with a population  in excess of 1 million, if the Administrator determines that  emissions 
of hazardous air pollutants from such wells present  more than a negligible risk of adverse 
effects to public health [emphasis added].

This implies that the congressional intent is to restrict oil and gas site area source applicability 
requirements to urban areas with greater than 1 million people in MSA and CMSAs.

If you have any questions regarding this white paper or desire additional discussion surrounding 
this important issue, please contact me at the number below.  Thank you for your consideration of 
this request. 

      Matt


Matthew Todd
API
1220 L Street NW
Washington DC  20005
202.682.8319
www.api.org

