The Interstate Natural Gas Association of America (INGAA) respectfully submits these comments in response to the EPA Notice, “Proposed Information Collection Request; Comment Request; Information Collection Effort for Oil and Gas Facilities” (Proposed ICR).
EPA has issued the ICR to better understand existing sources in the oil and gas industry before the Agency embarks on an effort to develop standards of performance for existing oil and gas sources. INGAA is offering the following comments on the Proposed ICR, which will result in a better data collection effort and contribute to more informed rulemaking while reducing industry burden. Rulemaking should be based on the best available data, and much of the information is already available to EPA. INGAA is committed to working with EPA to ensure the best and most appropriate information is collected while minimizing the burden on industry.
In the pages that follow, INGAA has provided specific suggestions to address the issues that it has identified. Some of INGAA’s key comments include:
Details on these items and additional issues are included in INGAA’s comments here.