National Emission Standards for Hazardous Air Pollutants: Crude Oil and Natural Gas Production Facilities and Natural Gas Transmission and Storage Facilities; Technology Review and Reconsideration

Frank McKiernan, a law student at Elon University, argues that the EPA should maintain its original understanding of the D.C. Circuit's L.E.A.N. ruling. He supports the agency's obligation to regulate new emission points at crude oil and natural gas facilities to protect public health and fulfill the EPA's mission.

The Petroleum Alliance of Oklahoma, a trade association representing the oil and gas industry, expresses a mixed position on the proposed rule. They support the primary provisions (Approach 1), including revisions to the "associated equipment" definition and certain emission limit equations, but they oppose the co-proposed Approach 2, which would expand the scope of regulations to previously unregulated emission points.

The commenter provides technical feedback and data comparisons regarding the inclusion of methanol in NESHAP subpart HHH and the use of the ProMax model for emissions calculations. They suggest specific monitoring requirements, such as adding methanol to wet gas samples and considering reboiler temperature monitoring, based on their own simulation results.

Earthjustice, Sierra Club, and Environmental Defense Fund are requesting a 45-day extension of the comment period for the proposed rule on National Emission Standards for Hazardous Air Pollutants from oil and gas facilities. They argue that the current 60-day period is insufficient for commenters to assess the complex legal changes and gather the extensive technical data the EPA has requested.

The commenter argues that the EPA's proposed interpretation of its obligations under section 112(d)(6) of the Clean Air Act is inconsistent with the D.C. Circuit's decision in *LEAN v. EPA*. They contend that the EPA is required to address regulatory gaps and missing emission limits for all hazardous pollutants during technology reviews, rather than deferring action on unregulated emission points.

The GPA Midstream Association is requesting a 45-day extension to the public comment deadline for the proposed rule. They argue that the complexity of the proposal, particularly regarding methanol regulation, requires more time for their members to conduct necessary technical and engineering analyses.

The commenter argues that the EPA's proposed interpretation of the *LEAN* decision is incorrect and that the Agency is legally obligated to establish emission standards for all hazardous air pollutants (HAPs) during technology reviews, including those from previously unregulated emission points. They also criticize the EPA for failing to provide sufficient evidence to justify not adopting standards for methanol injection in large glycol dehydration units.

A medical oncologist argues that rolling back the proposed regulations will lead to increased rates of cancer and other respiratory diseases in Americans. The commenter cites peer-reviewed medical research to support the claim that petroleum production and transmission facilities contribute to significant health risks.

The Hip Hop Caucus, an advocacy organization focused on environmental justice, urges the EPA to strengthen the proposed rule by regulating previously unregulated emission points and preventing "backsliding" from major-source reclassifications. They also advocate for faster compliance timelines for natural gas-driven process controllers and require more transparent public reporting and accountability for facilities in overburdened communities.