FR 2025-01091

The document is a proposed rule by the Environmental Protection Agency (EPA) that is part of ongoing efforts to regulate pollutants associated with the oil and natural gas industry. The proposed changes are in response to public petitions urging the EPA to reconsider previously established standards. Importantly, this proposal also addresses corrections to the data collected during information collection processes, critical for assessing compliance with rules governing emissions.

General Summary

The proposed rule seeks to amend current performance standards and guidelines specific to the oil and natural gas sectors. The EPA is revisiting some standards following petitions that requested a reevaluation. Additionally, the rule aims to rectify certain incorrect estimates related to information gathering highlighted in a previous notice. The EPA invites the public to share their opinions on the proposed corrections by March 3, 2025, providing several avenues for public comment, including online submission and email.

Significant Issues and Concerns

Several issues emerge from this proposal:

• Lack of Clarity in Information Collection: The document lacks specific details on what types of records or reports are required from respondents. This could create confusion and difficulty for those obligated to comply, as the terms are not clearly defined.

• Vague Definitions of 'Exigent Circumstances': The proposal references instances where an "associated gas extended flaring allowance" may be used due to "exigent circumstances." However, it fails to clearly define what qualifies as such circumstances, potentially leading to inconsistent interpretations.

• Cost and Burden Estimates: The rule provides estimates for the costs and burdens associated with compliance but lacks detailed justifications. Without this detail, stakeholders might question the calculations' validity, potentially undermining confidence in the proposal.

• Speculative Elements: The mention that a "maximum of 16 percent of flaring events" might require extended actions seems speculative. More empirical data and solid evidence could bolster understanding and support for this estimate.

• Technical Language: The use of technical jargon could obscure understanding for some stakeholders, especially those unfamiliar with regulatory or scientific terms, leading to misunderstandings.

Impact on the Public and Stakeholders

Public Impact

For the general public, these proposed changes intend to ensure that emissions from oil and natural gas operations are kept within safe and manageable levels, theoretically leading to an improved environmental outlook. However, a lack of clarity and detailed justification could lead to public skepticism regarding the effectiveness and fairness of these measures.

Impact on Stakeholders

For oil and natural gas operators and owners, these changes imply an additional obligation to adhere to revised standards and potentially new recordkeeping requirements. While some might view these as onerous, such regulations are deemed necessary by the EPA for adequate environmental protection. The notion of "exigent circumstances" is particularly relevant for stakeholders, as it may impact operations and compliance activities.

To conclude, while the EPA's proposed rule represents part of a broader environmental policy aimed at reducing harmful emissions, it will benefit significantly from more precise language and detailed evidence supporting proposed measures. Engaging effectively with stakeholders, through clear communication and justifications, will be crucial for ensuring compliance and achieving the desired environmental outcomes.

The document from the Environmental Protection Agency (EPA) discusses financial estimates and burdens related to compliance with proposed environmental regulations for the crude oil and natural gas sector. It highlights the anticipated costs and hours required to meet new recordkeeping and reporting requirements under the revised information collection request (ICR).

One of the key financial elements mentioned is the estimated average annual burden associated with these requirements. The document reports that owners and operators would spend an average of 83 person-hours annually at a cost of $4,374 over a three-year period. This figure is meant to account for the time and resources operators need to comply with new guidelines, though the basis for these specific numbers is not fully explained, as noted in the issues section.

Additionally, there is an incremental cost increase associated with event-specific recordkeeping requirements. For each event where extended flaring might occur under “exigent circumstances,” the cost is estimated at $120 per flaring event over the three-year span from 2024 to 2026. The surrounding text expresses concerns over the lack of a clear definition for "exigent circumstances," which may impact the perceived validity of these cost projections.

Moreover, the document lists a total estimated cost of $15,444 annually, including $6,576 in capital or operation and maintenance costs. This annual estimation attempts to encapsulate all expected financial burdens, yet how these numbers were calculated could be clearer to ensure stakeholders comprehend the anticipated financial impact fully.

Overall, the document ties financial references to specific compliance activities, aiming to offer a comprehensive view of the financial implications faced by the oil and natural gas sector. However, criticisms regarding the lack of detailed justification for these costs could challenge the perceived transparency and reliability of the financial estimates provided. Furthermore, the use of technical language and vague conditions like "exigent circumstances" may hinder some stakeholders from fully understanding the financial burdens they are facing.