Anonymous public comment

I am an engineer with a nation-wide firm. I have thought long and hard in regards to the rumors of amending the deadline for farmers to comply with the SPCC regulations. I feel compelled to communicate that this extension will cost thousands of U.S. citizens their jobs. My firm employs roughly 200 people throughout the U.S. I prefer to remain anonymous because I am an engineer and not an owner of the company. However, this extension affects my family and I drastically, along with thousands of other hard working folks. I would like to point out that there is a free template for self-certified SPCC plans on www.epa.gov. I know our firm is not the only one that offers both PE plans and assistance for producers who need help with the template on your website. I have been in the industry for a long time and I have seen the enforcement brought upon oil and gas producers. It may be rude of me to say, but it is not fair to allow farmers to be exempt from enforcement when you, the EPA, are so stringent upon oil and gas producers. Perhaps the most important part of my statement is that, this extension is ONLY for farmers and ranchers that have started production after August 16, 2002. My guess is that is less than, 100,000 farms. I can count on one hand how many fines have been issued to farms due to SPCC violations when there are multiple fines every day in the oil and gas industry. My guess is if you fined a farmer in each state once a day every week for SPCC violations, you wouldn’t even need an extension beyond 6 months from the date of the first fine. They want to comply although they may not agree with the regulations. If they see the consequences, I believe they will be more inclined to complete their SPCC requirements. Normally I can state that I understand the other point of view, in this case I have absolutely no idea why your agency would extend the deadline another 18 months when our firm and multiple others are ready to help farmers with your regulations!