Letter to EPA Assistant Administrator for Air Gina McCarthy Regarding Oil & Gas NSPS

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Subject: Oil and Natural Gas Sector: New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants Review
Recipient: EPA Assitant Administrator for Air & Radiation Gina McCarthy
Sender: Lisa S. Beal
Date Sent: October 11, 2011

     EPA’s recently proposed oil and natural gas regulations are portrayed as regulating emissions of volatile organic compounds (VOCs). These rules would have far-reaching impacts on our industry, yet, for natural gas transmission and storage companies, VOC emissions are relatively minimal. This leads us to believe that the actual aim of these proposed standards is to regulate greenhouse gases (GHGs).

     As the trade association representing the nation’s interstate natural gas transmission pipelines, the Interstate Natural Gas Association of America strongly objects to these proposed regulations because they do not address VOCs but instead clearly target GHG emissions. INGAA writes to express our concerns, and we respectfully ask to meet with you to discuss the points raised in this letter in greater depth.