1. Oil & Gas NSPS/NESHAPS Bob Lebens WESTAR Bob Lebens WESTAR

2. Oil & Gas NSPS/NESHAPS  Oil & Gas Federal Regulatory History  Current Proposal  Compared to State Programs  Basin Impacts  Schedule  Oil & Gas Federal Regulatory History  Current Proposal  Compared to State Programs  Basin Impacts  Schedule

3. Oil & Gas NSPS/NESHAPS  1985 NSPS - Gas Processing Plants  1999 O&G Production, Storage Transport MACT  Gas Star Voluntary Program  2011 NSPS/NESHAPS  Oil & Gas  Extraction  Distribution  Pipeline Transportation of Gas  1985 NSPS - Gas Processing Plants  1999 O&G Production, Storage Transport MACT  Gas Star Voluntary Program  2011 NSPS/NESHAPS  Oil & Gas  Extraction  Distribution  Pipeline Transportation of Gas

4. Oil & Gas NSPS/NESHAPS  Applies to 25,000 wells fractured/refractured each year  Storage tanks and other associated equipment  Emission Reductions  VOCs: 540,000 tons, 26% reduction  Methane: 3.4 million tons, 26% reduction (through VOC controls)  O&G = 40% US methane emissions  Air Toxics: 38,000 tons, 30% reduction  Applies to 25,000 wells fractured/refractured each year  Storage tanks and other associated equipment  Emission Reductions  VOCs: 540,000 tons, 26% reduction  Methane: 3.4 million tons, 26% reduction (through VOC controls)  O&G = 40% US methane emissions  Air Toxics: 38,000 tons, 30% reduction

5. Compared to State Regulations  Wyoming, Colorado  Most comprehensive and stringent Oil & Gas control requirements  Alaska, Montana, New Mexico, North Dakota, Utah  Some States have limited minor source programs  Complete Analysis in WRAP Report  Wyoming, Colorado  Most comprehensive and stringent Oil & Gas control requirements  Alaska, Montana, New Mexico, North Dakota, Utah  Some States have limited minor source programs  Complete Analysis in WRAP Report

6. Basin Impacts  San Juan, New Mexico  Older equipment remains in place  New Basins - Pieance, Colorado  Newer, cleaner equipment  San Juan, New Mexico  Older equipment remains in place  New Basins - Pieance, Colorado  Newer, cleaner equipment

7. Schedule  Proposal Comments due November 30, 2011  EPA seeking comment in 65 areas  Promulgation  Court ordered deadline - February 28, 2012  Proposal Comments due November 30, 2011  EPA seeking comment in 65 areas  Promulgation  Court ordered deadline - February 28, 2012