American Oil and Gas Reporter - October 2016 - 109

of its dam at Joe Pool Lake in the DallasFort Worth metropolitan area, which includes the Barnett Shale, Mills says.
"The issue hasn't been resolved, but it's
an example of continued federal overreach
into a state issue," he argues. "The Obama administration continues to come at the
industry from all angles."
Air Quality
The Alliance opposed a Dallas City
Council resolution asking the Texas Commission on Environmental Quality to take
additional measures to reduce ozone levels in the Dallas-Fort Worth area. Mills
says the Alliance joined other associations
in penning a letter opposing the resolution,
based on concerns it would impose significant costs on the industry without providing equivalent air quality benefits.
"(The council) passed it, but it doesn't
mean much," Mills assesses. "There isn't
any natural gas production in the city of
Dallas. It's like the state of Vermont banning hydraulic fracturing. The prevailing
wind in the Dallas-Fort Worth area is
southwest to northeast and Dallas sits south
of the Barnett shale."
The Alliance continues to engage in its
statewide campaign, I am Texas Oil, which
is designed to show lawmakers, regulators
and the public that the industry consists of
real people who share similar aspirations,
and provides jobs and other benefits to the
state as a whole, Mills goes on.
The association's campaign included a
show of support at the Sunset Commission's August public hearing on the RRC
sunset, he recalls. "We brought in people
and developed an 'I am Texas Oil' button,"
Mills says. "These folks included small oil
and gas producers from across the state."
EPA Lawsuit
The Alliance is participating with other associations in a lawsuit against the U.S.
Environmental Protection Agency filed in
the U.S. Court of Appeals for the District
of Columbia Circuit, seeking review of fi-

nal regulations setting methane emission
standards for new, reconstructed and
modified oil and gas operations, Mills says.
Alliance Executive Vice President
John Tintera says, "The Alliance feels the
methane rule is an example of federal overreach to curtail oil and gas production and
raise the cost of compliance while getting
minimal benefits."
He points out that EPA's initial proposal did not include stripper wells, which
contribute few methane emissions. But
EPA's final rule for new or modified
sources, as well as an information request
on expanding the limits to existing sources,
would extend restrictions to all wells, regardless of production volume.
"One size does not fit all in the oil
patch," Tintera insists. "It is an example
of so many efforts by the federal government to extend its regulatory reach into the
oil field in individual states."
Also on the federal front, the Alliance
continues to monitor a proposal by the Department of Transportation's Pipeline and
Hazardous Materials Safety Administration to change the definition of natural gas
gathering and transportation lines subject
to federal regulations, Stevens mentions.
Current definitions are based on American Petroleum Institute standards, but he
says PHMSA's proposed changes include
requiring operators to replace miles of eightinch polyethylene flowlines with steel
pipe, which could cost billions of dollars.
State Regulatory Relief
On the state regulatory front, Tintera says
the Alliance welcomes Railroad Commissioner Christi Craddick's Texas Oilfield Relief Initiative announced Aug.9 to reduce the
administrative burden on industry while ensuring the commission continues to protect
the public and environment.
Craddick's plan would eliminate redundant or unnecessary reports and filings,
amend Statewide Rule 28 to modify gas
well deliverability reporting requirements,
reduce the need for G-10 (gas well status)

filings except for surface-commingled
production, and allow operators to use a
calculated well shut-in pressure when
filing Form G-10, according to an RRC
summary.
Craddick also wants to amend the
definition of an active oil well in SWR 15
from 10 barrels of oil a month for three
consecutive months to five barrels a
month over that period, the summary
states. The definition of an active gas well
would be lowered from 100 Mcf a month
to 50 Mcf a month.
"This would eliminate unnecessary
reporting that many in industry see as a
holdover from earlier days and recognizes
changing economics in defining an active
well versus an inactive well," Tintera
says.
A requirement to submit a G-10 report
of annual production or pressure testing is
another outdated item, he continues.
"The RRC believes the G-10 may no
longer be serving the purpose it was intended to," Tintera expounds. "Those
data may be available in other places. (The
existing rule) requires many operators to
shut in wells to test them, which is expensive. The data that are gathered are not necessarily being used. The (relief proposal)
eliminates the need to file annual G-10s.
We are very supportive of that."
He comments that testing or shutting
in marginal wells can be problematic
and damaging. "The older the well is, the
riskier it is to shut in," he remarks.
The RRC has done exemplary work
plugging 30,000 orphaned wells, Tintera
praises.
"Inactive wells cause oil and gas operators a lot of problems," he says. "The RRC
requires operators to address inactive
wells, but operators are concerned about being forced to plug wells prematurely because of the existing definitions and plugging requirements. The proposed changes
will help operators avoid that trap. I give
a hats-off to Commissioner Craddick for
coming up with these ideas."
r

New York

IOGA NY Fighting Regulatory Threats
By Dan Holder
HAMBURG, N.Y.-Operators across
the country struggle to comply with state
and federal regulations, but Brad Gill, executive director of the Independent Oil &
Gas Association of New York, says his
state has taken an anti-industry attitude to
a new level by, in some cases, ordering
compliance with as-yet unissued rules.

The state-highlighted by its 2014 prohibition against high-volume hydraulic
fracturing-is a contributing reason IOGA
NY opted to cancel its 2016 annual convention, which was scheduled for Oct. 20,
Gill says.
"I am wearing this phrase thin, but I call
it targeted regulatory harassment," he
says. "We thought when (Governor Andrew) Cuomo was successful in shutting

down New York's unconventional industry, that would be the end of it and the association would shrink back to where it
was a few years ago, representing conventional operators who would be able to remain active and thrive in New York."
Instead, Gill asserts New York officials
seem determined to stamp out any remaining pockets of oil and gas activity. His latest evidence comes from the Department
OCTOBER 2016 109

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