The U.S. Environmental Protection Agency announced that it is withdrawing its request that owners and operators in the oil and natural gas industry provide information on equipment and emissions at existing oil and gas operations.

The withdrawal is effective immediately, meaning owners and operators – including those who have received an extension to their due dates for providing the information – are no longer required to respond.

This action also comes after the agency received a letter on March 1, 2017, from nine state Attorneys Genera...

Here is the EPA Request that was Eliminated by Pruitt

EPA’s Actions to Reduce Methane Emissions from the Oil and Natural Gas
Industry: Final Information Collection Request for Existing Sources
Overview
 On Nov. 10, 2016, the U.S. Environmental Protection Agency (EPA) issued a final
Information Collection Request (ICR) to require oil and natural gas companies to provide
information needed to develop regulations to reduce methane emissions from existing
sources in the oil and natural gas industry. The final ICR marks a critical step toward
meeting the Obama Administration’s commitment to reduce emissions from existing oil and
gas sources, as part of the President’s Climate Action Plan: Strategy to Reduce Methane
Emissions.
 Methane, the key constituent of natural gas, has a global warming potential more than 25
times greater than that of carbon dioxide. Methane is the second most prevalent
greenhouse gas emitted in the United States from human activities, and nearly one-third of
those emissions come from oil production and the production, processing and transmission
of natural gas. The oil and gas industry is the largest industrial methane source.
 The ICR seeks a broad range of information, such as how equipment and emissions controls
are, or can be, configured, and what installing those controls entails. This information will
help the agency determine how best to address methane emissions from the oil and gas
industry, including through rulemaking to reduce emissions. The final ICR reflects a number
of changes EPA made based on comments the agency received on two drafts of the ICR
issued earlier this year for public comment.
 EPA has designed the ICR so that it will not duplicate information industry already must
submit through federal programs such as the Greenhouse Gas Reporting Program. Under
the final ICR, industry will provide information on numerous sources and activities, including
natural gas venting that occurs as part of existing processes or maintenance activities, such
as well and pipeline blowdowns, equipment malfunctions and flashing emissions from
storage tanks. Recent studies have identified these processes and activities as likely large
sources of methane emissions. The ICR also seeks information on existing low-producing
wells.
 In accordance with the Clean Air Act, ICR recipients have a legal obligation to respond and
to attest to the accuracy of the information they provide.
What the Final ICR Covers
 The ICR seeks information from the following segments of the oil and gas industry: onshore
production, gathering and boosting, gas processing, transmission, storage, and liquefied
natural gas (LNG) import/export. It does not request information from offshore production
or local natural gas distribution facilities that provide gas to businesses and homes.
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 Like the two draft ICRs that were made available for public comment earlier in 2016, the
final ICR comprises two parts:
 An “operator survey” designed to obtain readily available information on the number
and types of equipment at all onshore oil and gas production facilities in the United
States; and
 A “facility survey,” to collect detailed information on emissions sources and emissions
control devices or practices in use at facilities in the onshore production, gathering
and boosting, processing, compression/transmission, pipeline, natural gas storage,
and LNG storage and import/export facilities. EPA expects much of the information
requested in the facility survey to be readily available from company records;
however, owners/operators may have to collect some information – such as counts
of pneumatic devices. This more detailed survey will be sent to a representative
sample of facilities rather than to all facilities, in order to reduce the burden to the
industry.
 The operator survey will be sent to approximately 15,000 owners/operators in the oil and
gas industry; the more detailed facility will be sent to approximately 4,650
owners/operators.
 EPA carefully considered comments on both drafts of the ICR and has made a number of
changes that are reflected in the final ICR to improve the information the agency receives
and to reduce the burden on industry. Those changes include:
 Providing additional time to respond to both surveys. The final ICR provides owners/
operators 60 days to respond to the operator survey and 180 days to respond to the
facility survey. Under the second draft ICR, owners/operators would have had 30
days to respond to the operator survey and 120 days to respond to the facility survey.
 Categorizing wells based on their gas-to-oil ratio (GOR). The GOR indicates whether
the primary product of a well site is likely to be oil or gas, which, in turn, will give EPA
information about the types of equipment likely to be located at the site. For each
GOR category, the ICR seeks information on low-production wells, which produce 15
barrels of oil equivalent per day on average over a 12-month period, and wells that
are not low production.
 Shifting certain questions from the operator survey to the facility survey. Under the
final ICR, questions about access to electricity, the number of facilities that are
manned or unmanned, liquids unloading, and hydraulic fracturing have been moved
from the broader operator survey to the facility survey, which will reduce the
reporting burden for the industry.
 Splitting the gathering and boosting segment of the industry into two segments to
reduce confusion. The final ICR splits the gathering and boosting segment into
compressor stations and pipeline facilities (pipeline facilities are defined as the
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collection of pipelines and associated equipment on a county basis). These segments
are covered by the facility survey. Owners/operators will be asked to enter basic
information about all of all of their gathering and boosting compressor stations and
pipeline facilities and provide more detailed information for about 10 percent of
those, which will be randomly selected.
 Changed the required methods for pressurized liquids sampling. This sampling, which
applies to separators with a throughput of more than 10 barrels per day, will provide
information on potential flashing emissions when pressurized liquids enter
atmospheric storage tanks. The final ICR requires owners/operators to use one of
three Gas Processors Association sampling method, depending on the type of liquid
they are sampling. The methods are specified in the ICR.
 Asks owners/operators to voluntarily provide information about costs such as the
cost of controls -- that will help EPA better understand the economics of oil and
natural gas wells.
Making a number of clarifications, including:
 Who is responsible for responding: The final ICR makes clear that the person
or entity owning or operating a facility at the time the ICR letter is received is
responsible for responding.
 How owners/operators must report information on wells at surface sites and
the centralized production areas those wells feed.
 The portion of wells the facility survey covers: The final ICR clarifies that the
facility survey will not request detailed information on every well in the
industry; rather, it will focus the detailed information request on randomly
selected wells, asking for details on those wells, other wells and equipment at
that same surface site as the randomly selected well(s) and the centralized
production sites those wells feed.
 EPA estimates the industry cost of responding to the ICR at about $42 million: $18 million to
respond to the operator survey and $24 million to respond to the more detailed facility
survey.
Responding to the final ICR
 Owners and operators will receive the ICR by registered mail and are required to respond.
There are two deadlines for responding:
o Recipients of the operator survey (also referred to as Part 1) will have 60 days after
receiving the ICR to complete the survey and submit it to EPA. Owners/operators
may download the operator survey from EPA’s website at
https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry/oil-andgas-industry-information-requests
. Owners/operators may submit the operator
survey electronically or by hard copy. Instructions for submitting responses are
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included in the ICR letter.
o Recipients of the more detailed facility survey (also referred to as Part 2) will have
180 days after receiving the ICR to complete that survey and submit it to the agency.
To make it easier for industry to submit responses to the facility survey, EPA will use
the agency’s electronic Greenhouse Gas Reporting Tool (e-GGRT) to collect the data
and information from the facility survey.
 Owners/operators with questions about responding to the ICR may the call the contact
listed in their ICR letter. Owners/operators responding to the Part 2 facility survey also may
contact the e-GGRT Help Desk for assistance at
https://ccdsupport.com/confluence/display/help/Contact+the+Help+Desk .
Background
 The ICR process, which is governed by the Paperwork Reduction Act, provides the public
two opportunities to review drafts of the ICR and supporting materials. EPA issued two
drafts of the ICR: an initial draft, published in the Federal Register June 3, 2016, and a
second draft, published Sept. 29, 2016.
 EPA announced its plans to issue the ICR on March 10, 2016, as part of a joint commitment
between the U.S. and Canadian governments to take new actions to reduce methane
pollution from the oil and gas sector, including developing regulations to reduce methane
emissions from existing sources. The ICR is the first step in that process; the information
that companies will be required to collect and report to EPA will provide the foundation
necessary for developing comprehensive regulations to reduce emissions from existing
sources in the large and complex oil and gas industry.
 Over the past year, substantial amounts of new information on methane emissions from
existing sources, operations and activities in the oil and gas industry have become available
from a range of entities, including EPA’s Greenhouse Gas Reporting Program, industry
organizations, and studies by government, academic and industry researchers. That
information shows that methane emissions from existing sources – sources not covered by
the NSPS issued May 12 -- are higher than previously understood.
 While this recent information has substantially improved EPA’s understanding of the
magnitude of emissions from existing oil and gas sources, the agency needs information
that is not currently available to develop standards for existing sources under section 111(d)
of the Clean Air Act for existing sources and to evaluate the impact of those standards.
 Unlike new source performance standards, which are triggered when a source is newly
constructed or modified, standards for existing sources likely would apply to all covered
processes and equipment at the same time. There are hundreds of thousands of existing oil
and gas sources across the country: some emit small amounts of methane, but others emit
methane in very large quantities.
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 To determine how to effectively and efficiently address emissions from those sources, EPA
needs information that is different from the information the agency needed to develop the
NSPS issued in May, such as what emission controls are being used in the field, how those
are configured, whether electricity or generating capacity is available, and how often sites
are staffed or visited.
 These types of information will help EPA determine how the agency can, working with
states, best develop and apply standards to effectively reduce emissions from existing
sources. It also will help identify sources with high emissions and the factors that contribute
to those emissions. The information EPA receives will build on what state and other federal
agencies have learned through their own rules, programs and experiences.
For More Information
 To read the final ICR and the surveys owners/operators are required to answer – visit
https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry/oil-and-gasindustry-information-requests
 For information on the New Source Performance Standards for new, modified and
reconstructed sources announced in May 2016, see: https://www.epa.gov/controlling-airpollution-oil-and-natural-gas-industry/new-source-performance-standards-and  


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