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 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 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.