Dear Administrator Regan:

The Permian Basin Petroleum Association (“PBPA”) is the largest regional oil and gas association in the United States. We represent the men and women who work in the oil and gas industry in the Permian Basin of West Texas and southeastern New Mexico. The Permian Basin is the largest inland oil and gas reservoir and the largest oil and gas producing region in the world. PBPA consists of the largest producers as well as the smallest operators in the Permian Basin. Part of PBPA’s mission is to promote environmentally conscious operations and sustainable economic profitability among all our members, large and small. Because PBPA’s members will be directly impacted by this Proposed Rule, if finalized, we are submitting these comments to convey our concerns and needed revisions.

INTRODUCTION

PBPA membership understands there are Congressional requirements placed on the Environmental Protection Agency (“EPA”) to draft a rule implementing the Inflation Reduction Act (“IRA”) as to, what EPA is now calling, the WEC. However, such an implementation of the IRA should reflect the statutory language and Congressional intent of the IRA. After a review of the Proposed Rule, we find numerous areas that do not accomplish this end.

As described in more detail below in these comments, PBPA believes there are unnecessary, and hopefully unintended, complications that will result from the Proposed Rule if implemented as drafted. For instance, there needs to be clarity around netting, adjustments to certain proposed time periods, exemptions and standards that are attainable under real world circumstances, as well as other changes that are necessary, and recommended herein, to actually effectuate the purposes of the IRA in the WEC.

PBPA appreciates this opportunity to comment on EPA’s Proposed Rule. These and other comments are further detailed below. To better align with the IRA, EPA’s expressed aim and to address the concerns detailed herein, PBPA requests...

Official Comments