American Oil and Gas Reporter - April 2018 - 166

industry today are completely bound to
follow the entire Subpart OOOOa methane
and VOC regulations."
But, he said, "Now that President
Trump has some of his people in place,
EPA is . . . a little more willing to consider
industry input."
One change being proposed, Venditti
revealed, is restoring an exemption for
wells making less than 15 barrels a day
that was part of the initial proposed
rule, but was not included in the final
regulation.
Also early in the rule making, Venditti
recalled, EPA considered a definition of
hydraulic fracturing that limited it to
"tight formations with extended flowback.
We don't really fall under that. We are
going to look at that definition again to
see if we can provide some relief specifically to our basin."
In addition, "We also are proposing
EPA scale back the documentation requirements," he announced.
As part of the effort to obtain relief
from Subpart OOOOa, immediate pastPresident Bryan Dicus said IOGA had
contributed $10,000 to help fund a study
being conducted by the Research Partnership to Secure Energy for America to
obtain more accurate data on methane
emissions from marginal wells than EPA
used as the basis for its 2016 rule.
While the Illinois Basin is not being
included in the direct measurements,
Dicus said RPSEA likely would seek information from Illinois operators. "They
are going to extrapolate the data from
the study across the country," he explained.
"So if that operator survey comes to
fruition, don't be afraid of it. It's private;
I don't think they will ask for any details
other than number of wells, average production and so forth. It is very important
to the study that we all participate."
On another federal matter, current
IOGA President Craig Hedin, vice president and general counsel of Gesell's
Pump Sales & Service in Whittington,
Il., said the association was asking the
director of the Illinois Environmental
Protection Agency to help convince the
U.S. EPA that it was unnecessary for the
federal agency to regulate oil field wastes
under Subtitle D of the Resource Conservation and Recovery Act.
He recalled that in 1988, oil field
wastes were exempted from regulation
as RCRA Subtitle C hazardous wastes.
But as part of that amendment, EPA was
directed to review every three years
whether oil field operations ought to be
included under Subtitle D nonhazardous
waste. "This kind of fell through the
cracks, so the environmental community
sued," he said.

The Illinois Oil & Gas Association is
working with other industry groups to
convince the U.S. Environmental Protection Agency to make changes to its
New Source Performance Standards for
oil ﬁeld emissions of carbon dioxide
and volatile organic compounds under
Subpart OOOOa, Charles Venditti, manager of regulatory compliance for Countrymark Energy Resources LLC, tells
IOGA members.

In December 2016, Hedin related,
EPA signed a consent decree, agreeing
to decide by March 15, 2019, whether
oil field wastes ought to be regulated
under RCRA Subtitle D. And while the
U.S. EPA can't force states to regulate
oil field wastes under Subtitle D, the existence of federal rules could give private
citizens a cause of action to bring lawsuits
against state agencies for failing to do
so, Hedin advised.
"A group of us explained the situation
to the director of the Illinois EPA," he
revealed. "We are asking him to write
the U.S. EPA saying Illinois doesn't
need any more federal regulations under
this statute.
"This is something associations across
the nation are doing," Hedin added.
"Hopefully, it will have some sway on
how the U.S. EPA makes the determination
by the March 2019 deadline."
Ad Valorem Taxes
Closer to home, Hedin reported IOGA
had intervened on a potential problem related to oil and gas ad valorem taxes. He
noted that operators could get a 33 percent
deduction on their ad valorem assessments
if the subject oil was produced through a
qualified enhanced recovery project, and
a 66 percent deduction if the EOR project
was more than 20 years old.
But the 2018 Oil and Gas Assessment
Schedule requires any operator claiming
the deduction to file a form OG-17. "What
the heck is an OG-17?" Hedin exclaimed.
It is an IDNR form for reporting in-

166 THE AMERICAN OIL & GAS REPORTER

jection pressures and volumes filed by
some, but not all, operators, he answered.
He explained that county assessors
feared some operators were claiming disposal wells as EOR injection wells. "They
just assumed everybody filed an OG-17
and that it had the information they wanted," he reflected.
Hedin said IOGA met with the county
assessors committee, which "was sympathetic." He said the chairman of the assessors
committee agreed to send a letter to all
county assessors, suggesting they not
require an OG-17 form for claiming the
EOR deduction this year. "We agreed to
meet again to see what we could come up
with to address this issue for 2019," he
added. "I wanted to alert you. If you have
any problems, give IOGA a call."
IOGA Awards
During its annual awards banquet,
held on Feb. 28, IOGA recognized Roger
Meier, drilling fluids manager for Franklin
Well Service, as its 2018 service person
of the year; independent petroleum engineer George A. Payne as its petroleum
professional of the year; Kathy Lloyd,
director of land & regulatory for CountryMark Energy Resources, as its petroleum professional woman of the year;
and Campbell Energy LLC as its wildcatter
of the year. In addition, IOGA presented
its 2018 Lifetime Achievement Award to
J. Roy Dee III, president of Dee Drilling
in Mt. Carmel, Il.
According to IOGA, Meier began his
oil field career in 1977 as a drilling fluids
engineer with Dresser-Magcobar, where
he was promoted to district engineer in
1986. He remained in that position when
Dresser-Magcobar merged with Halliburton in 1987 to form MI Drilling Fluids.
When MI left the tri-state area in 1992,
Meier joined Schwartz Drilling Fluids
Co. as vice president of drilling fluids,
and then moved to Franklin Well Service
as drilling fluids manager in 2002.
"Over the past 16 years, he has reintroduced Halliburton Baroid products to
the Illinois Basin and has played a key
role in expanding Franklin's market share,"
IOGA states. "Although his main area of
expertise is drilling fluids, he also has
been involved in overseeing Franklin's
cementing, acidizing and fracturing operations."
Payne sandwiched three years' service
in the U.S. Navy between earning a B.S.
in petroleum engineering from the University of Oklahoma in 1970 and an M.S.
from the University of Tulsa in 1975.
He began his oil field career with Scientific Software Corporation in Denver
before moving to the Illinois Basin in
1979. There, IOGA says, Payne "has

American Oil and Gas Reporter - April 2018

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