WASHINGTON, Jan. 20 -- Joan Dreskin, senior vice president and general counsel at the Interstate Natural Gas Association of America, has issued a public comment on the Environmental Protection Agency proposed rule entitled "Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review". The comment was written on Nov. 8, 2021, and posted on Jan. 18, 2022:
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The Interstate Natural Gas Association of America (INGAA), the national trade association addressing issues of importance to the natural gas pipeline industry in North America, respectfully requests an extension of time to comment on EPA's recently released proposed rule entitled "Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review."
The proposed rule currently provides parties with 60 days to comment following the publication of the proposed rule in the Federal Register. INGAA respectfully requests that the deadline be extended an additional 30 days, allowing interested parties a total of 90 days to comment following Federal Register publication.
This extension is necessary because it raises issues arising for the first time. Specifically, the proposed rule sets forth emissions guidelines for existing sources under section 111(d) of the Clean Air Act.
The Crude Oil and Natural Gas source category (which is the source category at issue in the proposed rule) has never been regulated under section 111(d) before. Because this is a complex issue of first impression, an extension of time is needed to ensure all concerned parties have an opportunity to develop meaningful comments on these important issues.
Thank you for your consideration of this request.
Senior Vice President & General Counsel
25 Massachusetts Avenue, NW Suite 500N
Washington, DC 20001
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The proposed rule can be viewed at: https://www.regulations.gov/document/EPA-HQ-OAR-2021-0317-0001
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