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API: Implementing EPA’s Control Techniques Guidelines without proper scientific input is bad public policy

Reid Porter | | 202.682.8114

WASHINGTON, October 20, 2016 – API Senior Director of Regulatory and Scientific Affairs Howard J. Feldman cautioned that EPA and states should not pile on additional guidelines and regulations on the oil and gas industry until EPA completes its Oil and Gas Information Collection Request (ICR) and subsequent analyses.  

“Moving forward with these guidelines without robust data could impose unachievable emission reduction requirements on the industry, while adding potentially significant costs to the American economy, jobs, consumers and the environment. 

“Air quality has already improved dramatically over the past two decades and will continue to improve as the industry continues to deploy innovative technologies and the EPA and states implement existing standards, which are the most stringent ever. 

“The United States leads the world in both production of oil and natural gas and in the reduction of carbon emissions. We are second to no one. These environmental milestones are confirmed by EPA’s own GHG inventory, which has consistently shown a downward trend in emissions over the past decade, and by EIA data showing that carbon emissions have already reached 25-year lows due to the increased use of natural gas. These improvements are projected to continue.

“This is quantifiable support showing that increased U.S. energy production, improved air quality and environmental progress are not mutually exclusive. These trends are indicative of what our industry, when given the freedom to innovate, can achieve to improve the environment as we bolster our nation’s energy security. 

“In light of current and proposed state and federal regulations that address existing sources, it is better to allow completion of the ICR to inform whether CTGs are warranted and avoid the risks that acting on insufficient scientific data and conflicting guidelines could impose on the American public. If the EPA fails to follow the science, we call on Congress to avoid potential barriers to American economic and environmental progress.”

API has supported the Oil and Gas ICR so that any additional regulatory decisions would be based on sound science and better informed on actual emissions and cost impacts for existing sources. API also supports providing ample time for states and businesses to meet the ozone standards, which are set close to background levels.  

API is the only national trade association representing all facets of the oil and natural gas industry, which supports 9.8 million U.S. jobs and 8 percent of the U.S. economy. API’s more than 625 members include large integrated companies, as well as exploration and production, refining, marketing, pipeline, and marine businesses, and service and supply firms. They provide most of the nation’s energy and are backed by a growing grassroots movement of more than 30 million Americans.

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