Date:	August 30, 2016

To:	Brenda Shine, EPA/OAQPS/SPPD

From:	Jeff Coburn and Cassy Becker

Subject:	Meeting Record for August 25, 2016 meeting between
Representatives of TPA and Representatives of OAQPS (U.S. EPA)



On August 25, 2016, representatives of the U.S. Environmental Protection
Agency (EPA) and their contractor (RTI International) participated in a
meeting with representatives of Texas Pipeline Association (TPA). 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) comments provided to the EPA by
TPA on August 2, 2016. TPA provided a brief introduction to their
association and the following topics were discussed.

Confidential Business Information (CBI). TPA representatives provided a
general overview of the gathering and boosting operations in Texas. They
explained that the midstream market is very competitive, both at the
receiving and providing ends of the gathering lines. TPA representatives
requested that either the entirety of the identity of the ICR-responding
company and the facility that is the subject of the ICR should be
protected so that no connection can be made between the data and the
company or facility at issue or, if not, EPA should significantly expand
the data elements that are considered to be CBI to provide additional
protections. TPA representatives noted that the ICR would provide a
convenient bundling of data that either was not previously available or
not collocated in one document before. They were concerned that
competitors, especially competitors that may not be selected to respond
to the ICR, would be able to use the information provided in the ICR to
gain an advantage over the responding companies. EPA representatives
indicated that the use of e-GGRT as a reporting tool for Part 2 of the
ICR would offer CBI protection for any data submitted.  

CIPSEA. TPA representatives encouraged the use of Confidential
Information Protection and Statistical Efficiency Act of 2002 (CIPSEA)
in the collection of data under the ICR. They explained that CIPSEA
would protect the responding companies since any information provided
cannot be disclosed in an identifiable form and the information cannot
be used for any purpose other than a statistical purpose. 

Miscellaneous. TPA representatives requested more time to respond to the
ICR. They also stated that the ICR burden estimate was low due to the
effort required for equipment counts.  EPA representatives replied that
best available data is being requested in the ICR, which should reduce
the burden and ease time constraints.



Attachment 1

Participants in August 25, 2016 EPA/TPA Meeting

TPA Representatives

Celina Romero, Duggins, Wren, Mann, & Romero, LLP

Jaron Hill, The Williams Companies, Inc.

Thure Cannon, TPA

Don Lewis, Duggins, Wren, Mann, & Romero, LLP

Eric Tiemeyer, Energy Transfer

Charles Yarbrough, Atmos

U.S. EPA Representatives

Angie Carey

Brenda Shine

Bruce Moore

Jonathan Witt

Penny Lassiter

Matthew Witosky 

RTI International (EPA Contractor)

Jeff Coburn

Cassy Becker

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