Date:	July 27, 2016

To:	Brenda Shine and Jonathan Witt, EPA/OAQPS/SPPD

From:	Justin Spencer and Cassy Becker

Subject:	Meeting Record for July 27, 2016 meeting between
Representatives of IPAA and Representatives of OAQPS (U.S. EPA)



On July 27, 2016, representatives of the U.S. Environmental Protection
Agency (EPA) and their contractor (RTI International) participated in a
conference call with a representative of the Independent Petroleum
Association of America (IPAA). The names and affiliations of the
participants are included in Attachment 1. The purpose of the meeting
was to discuss the existing source oil and gas information collection
request (ICR) as it pertains to the oil and gas production facilities.
The following topics were discussed.

Economic Addition to the ICR. The IPAA representative stated that one of
their main concerns after reviewing the ICR was the lack of economic
information that is being requested from facilities. In particular, the
IPAA representative felt that 70% of small producers with old and/or low
producing wells (marginal wells) would be inadequately characterized by
the ICR.  IPAA felt that the addition of more economic-focused questions
to the ICR would allow the EPA to better understand the financial burden
of small producers to implement additional programs for existing
equipment. IPAA noted that the useful life of many of these marginal
wells is decided from a financial standpoint and that the addition of
any further financial burdens to these producers could diminish the
value of these wells and shorten their useful lives. The EPA stated that
the ICR would be complementary to other forms of information available
to the agency when they begin the rule making process. 

Challenges for Small Producers When Completing Part 2. The IPAA
representative stated that many of their small upstream members could
have issues in completing Part 2 of the ICR from both a financial and a
technical perspective. According to the IPAA representative, the
quantity of data required by Part 2 may be overwhelming to small
producers, especially as the data collection will be concurrent with
Subpart OOOOa and Subpart W compliance efforts, so that IPAA members may
not have the necessary resources available to complete the ICR.

Research Partnership to Secure Energy for America (RPSEA). The IPAA
representative mentioned that RPSEA was currently looking for research
proposals related to small producers. IPAA recommended that EPA contact
RPSEA to discuss emissions information needs for upstream producers, as
RPSEA is currently looking for upstream research opportunities.

EPA Response to Comments.  The IPAA representative expressed concern
that EPA’s timeline for addressing comments on the ICR would not allow
the agency adequate time to evaluate the issues.

Attachment 1

Participants in July 27, 2016 EPA/IPAA Conference Call

IPAA Representative

Lee Fuller

U.S. EPA Representatives

Angie Carey

David Cozzie

Joe Goffman

Amy Hambrick

Jodi Howard

Penny Lassiter

Brenda Shine

Lisa Thompson 

Melissa Weitz

Jonathan Witt

RTI International (EPA Contractor)

Cassy Becker

Justin Spencer 

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