American Oil and Gas Reporter - January 2015 - 194

The Presidential Papers
Kentucky Oil & Gas
Association
RUDY VOGT III
Member Manager
Cumberland Valley
Resources LLC
Frankfort, Ky.

FROM THE PRESIDENT
No matter what the head of the U.S.
Environmental Protection Agency says
about the number of new regulations
being promulgated by her agency, over
the last year KOGA has been busy commenting on several proposed regulations,
evaluating their potential impact, and informing association members on the complicated compliance issues.
Over the past two years, EPA has implemented new regulations through 40
CFR 60, Subpart OOOO, regarding eliminating methane emissions during fracturing treatments of natural gas wells,
and reducing volatile organic compound
emissions from multiple sources, including
storage vessels. We still are waiting on
EPA's response to comments on its proposed changes to the definition of the
waters of the United States (WOTUS).
Clean Water Act Section 404 compliance has been among the new challenges
facing Kentucky's industry. KOGA has
been working with the state Division of
Water and the U.S. Army Corps of Engineers to educate association members on
how to comply. This challenge was magnified with the proposed WOTUS rule
changes. Even though the Corps and EPA
have indicated they don't expect significant
changes to the number of Kentucky waterways that would be regulated under
that section, review of the proposed
changes concern KOGA members.
KOGA hired a consultant to help it
understand the poorly written proposed
new definitions and help decide how they
would affect Kentucky operators. It was
the determination of the consultant and
the KOGA Technical and Regulatory
Committee that the new definitions could
increase dramatically the frequency under
which Corps permits would be needed.
The poorly written definitions and the
use of the term "nexus" to include areas

adjoining waterways that would not be
included in the "affected area" would expand areas disturbed from not even needing
a nationwide permit to possibly needing
an individual permit. The potential new
permitting requirements would be very
burdensome to the small oil and gas operators in the commonwealth.
KOGA has filed comments with EPA
and the Corps of Engineers on its concerns
with the proposed definitions. The association also has benefited from its relationship with the Independent Petroleum
Association of American, and has communicated to IPAA what it sees as the effects on small operators in Kentucky.
Air Quality Rules
The Kentucky Division of Air Quality
has been tasked with implementing EPA's
new air quality regulations set out in Subpart OOOO, having to do with methane
emissions associated with fracturing gas
wells and VOC emissions, from storage
vessels and other sources. KOGA has
been working with the DAQ to help it understand the drilling, completion, and production processes associated with oil and
gas production in the commonwealth.
DAQ encountered issues with how to
regulate flow back from fractured gas
wells. Historically, its typical permitting
scenarios included point-source emissions
over long periods. KOGA helped the
agency understand and incorporate regulation of a source of emission that may
occur only for a few hours.
The result is a compliance guide published by DAQ, and available to Kentucky
operators on line and through the Division
of Oil & Gas, where an operator can determine easily if his operation requires
notification to the state, what control
measures are acceptable, and how and to
whom reporting should be done.

194 THE AMERICAN OIL & GAS REPORTER

It has yet to be seen exactly what the
DAQ will accept as far as reporting,
since only a very small number of gas
wells were drilled and fractured in 2014
and the annual reporting is not due until
early this year. Again, with consultant
help and working with DAQ, it was
agreed that tanks receiving less than 20
barrels of oil a day did not require any
notification or VOC control. This makes
life easy for Kentucky's small operators
who don't have access to in-house technical staff. There are very few leases in
the commonwealth that produce more
than 20 bbl/d into one tank.
Last year, KOGA members, along
with representatives from several state
government agencies, environmental
groups and other industries, were invited
by Kentucky Energy and Environmental
Secretary Len Peters to participate in a
work group to review state oil and gas
regulations, and to make proposals to
revise regulations that would address
what was seen by the group as public
concerns with the industry, as well as to
develop regulations that would address
new situations in the commonwealth,
such as deep horizontal drilling and production, and large-volume hydraulic fracturing.
An ad hoc committee of KOGA members has been put together to review and
help form some of the suggested new
regulations, which then will be referenced
by KOGA members on the work group.
It is the hope of the Energy and Environment Cabinet to have a legislative
package to submit to the Kentucky Legislature with solutions to a few issues
that the work group has developed and
can support. It is anticipated that the
work group will continue working
throughout 2015.
What ties the association's efforts together is the fact that KOGA is working
toward solutions, not simply complaining
about problems. We owe it to our industry
and our membership to embrace the challenges and do our best to minimize the
impacts. That is what we have dedicated
ourselves to over the past two years-and
the results are starting to show.
Ì

Coming In February
Special Report: Gulf of Mexico



American Oil and Gas Reporter - January 2015

Table of Contents for the Digital Edition of American Oil and Gas Reporter - January 2015

Contents
American Oil and Gas Reporter - January 2015 - Cover1
American Oil and Gas Reporter - January 2015 - Cover2
American Oil and Gas Reporter - January 2015 - 3
American Oil and Gas Reporter - January 2015 - 4
American Oil and Gas Reporter - January 2015 - Contents
American Oil and Gas Reporter - January 2015 - 6
American Oil and Gas Reporter - January 2015 - 7
American Oil and Gas Reporter - January 2015 - 8
American Oil and Gas Reporter - January 2015 - 9
American Oil and Gas Reporter - January 2015 - 10
American Oil and Gas Reporter - January 2015 - 11
American Oil and Gas Reporter - January 2015 - 12
American Oil and Gas Reporter - January 2015 - 13
American Oil and Gas Reporter - January 2015 - 14
American Oil and Gas Reporter - January 2015 - 15
American Oil and Gas Reporter - January 2015 - 16
American Oil and Gas Reporter - January 2015 - 17
American Oil and Gas Reporter - January 2015 - 18
American Oil and Gas Reporter - January 2015 - 19
American Oil and Gas Reporter - January 2015 - 20
American Oil and Gas Reporter - January 2015 - 21
American Oil and Gas Reporter - January 2015 - 22
American Oil and Gas Reporter - January 2015 - 23
American Oil and Gas Reporter - January 2015 - 24
American Oil and Gas Reporter - January 2015 - 25
American Oil and Gas Reporter - January 2015 - 26
American Oil and Gas Reporter - January 2015 - 27
American Oil and Gas Reporter - January 2015 - 28
American Oil and Gas Reporter - January 2015 - 29
American Oil and Gas Reporter - January 2015 - 30
American Oil and Gas Reporter - January 2015 - 31
American Oil and Gas Reporter - January 2015 - 32
American Oil and Gas Reporter - January 2015 - 33
American Oil and Gas Reporter - January 2015 - 34
American Oil and Gas Reporter - January 2015 - 35
American Oil and Gas Reporter - January 2015 - 36
American Oil and Gas Reporter - January 2015 - 37
American Oil and Gas Reporter - January 2015 - 38
American Oil and Gas Reporter - January 2015 - 39
American Oil and Gas Reporter - January 2015 - 40
American Oil and Gas Reporter - January 2015 - 41
American Oil and Gas Reporter - January 2015 - 42
American Oil and Gas Reporter - January 2015 - 43
American Oil and Gas Reporter - January 2015 - 44
American Oil and Gas Reporter - January 2015 - 45
American Oil and Gas Reporter - January 2015 - 46
American Oil and Gas Reporter - January 2015 - 47
American Oil and Gas Reporter - January 2015 - 48
American Oil and Gas Reporter - January 2015 - 49
American Oil and Gas Reporter - January 2015 - 50
American Oil and Gas Reporter - January 2015 - 51
American Oil and Gas Reporter - January 2015 - 52
American Oil and Gas Reporter - January 2015 - 53
American Oil and Gas Reporter - January 2015 - 54
American Oil and Gas Reporter - January 2015 - 55
American Oil and Gas Reporter - January 2015 - 56
American Oil and Gas Reporter - January 2015 - 57
American Oil and Gas Reporter - January 2015 - 58
American Oil and Gas Reporter - January 2015 - 59
American Oil and Gas Reporter - January 2015 - 60
American Oil and Gas Reporter - January 2015 - 61
American Oil and Gas Reporter - January 2015 - 62
American Oil and Gas Reporter - January 2015 - 63
American Oil and Gas Reporter - January 2015 - 64
American Oil and Gas Reporter - January 2015 - 65
American Oil and Gas Reporter - January 2015 - 66
American Oil and Gas Reporter - January 2015 - 67
American Oil and Gas Reporter - January 2015 - 68
American Oil and Gas Reporter - January 2015 - 69
American Oil and Gas Reporter - January 2015 - 70
American Oil and Gas Reporter - January 2015 - 71
American Oil and Gas Reporter - January 2015 - 72
American Oil and Gas Reporter - January 2015 - 73
American Oil and Gas Reporter - January 2015 - 74
American Oil and Gas Reporter - January 2015 - 75
American Oil and Gas Reporter - January 2015 - 76
American Oil and Gas Reporter - January 2015 - 77
American Oil and Gas Reporter - January 2015 - 78
American Oil and Gas Reporter - January 2015 - 79
American Oil and Gas Reporter - January 2015 - 80
American Oil and Gas Reporter - January 2015 - 81
American Oil and Gas Reporter - January 2015 - 82
American Oil and Gas Reporter - January 2015 - 83
American Oil and Gas Reporter - January 2015 - 84
American Oil and Gas Reporter - January 2015 - 85
American Oil and Gas Reporter - January 2015 - 86
American Oil and Gas Reporter - January 2015 - 87
American Oil and Gas Reporter - January 2015 - 88
American Oil and Gas Reporter - January 2015 - 89
American Oil and Gas Reporter - January 2015 - 90
American Oil and Gas Reporter - January 2015 - 91
American Oil and Gas Reporter - January 2015 - 92
American Oil and Gas Reporter - January 2015 - 93
American Oil and Gas Reporter - January 2015 - 94
American Oil and Gas Reporter - January 2015 - 95
American Oil and Gas Reporter - January 2015 - 96
American Oil and Gas Reporter - January 2015 - 97
American Oil and Gas Reporter - January 2015 - 98
American Oil and Gas Reporter - January 2015 - 99
American Oil and Gas Reporter - January 2015 - 100
American Oil and Gas Reporter - January 2015 - 101
American Oil and Gas Reporter - January 2015 - 102
American Oil and Gas Reporter - January 2015 - 103
American Oil and Gas Reporter - January 2015 - 104
American Oil and Gas Reporter - January 2015 - 105
American Oil and Gas Reporter - January 2015 - 106
American Oil and Gas Reporter - January 2015 - 107
American Oil and Gas Reporter - January 2015 - 108
American Oil and Gas Reporter - January 2015 - 109
American Oil and Gas Reporter - January 2015 - 110
American Oil and Gas Reporter - January 2015 - 111
American Oil and Gas Reporter - January 2015 - 112
American Oil and Gas Reporter - January 2015 - 113
American Oil and Gas Reporter - January 2015 - 114
American Oil and Gas Reporter - January 2015 - 115
American Oil and Gas Reporter - January 2015 - 116
American Oil and Gas Reporter - January 2015 - 117
American Oil and Gas Reporter - January 2015 - 118
American Oil and Gas Reporter - January 2015 - 119
American Oil and Gas Reporter - January 2015 - 120
American Oil and Gas Reporter - January 2015 - 121
American Oil and Gas Reporter - January 2015 - 122
American Oil and Gas Reporter - January 2015 - 123
American Oil and Gas Reporter - January 2015 - 124
American Oil and Gas Reporter - January 2015 - 125
American Oil and Gas Reporter - January 2015 - 126
American Oil and Gas Reporter - January 2015 - 127
American Oil and Gas Reporter - January 2015 - 128
American Oil and Gas Reporter - January 2015 - 129
American Oil and Gas Reporter - January 2015 - 130
American Oil and Gas Reporter - January 2015 - 131
American Oil and Gas Reporter - January 2015 - 132
American Oil and Gas Reporter - January 2015 - 133
American Oil and Gas Reporter - January 2015 - 134
American Oil and Gas Reporter - January 2015 - 135
American Oil and Gas Reporter - January 2015 - 136
American Oil and Gas Reporter - January 2015 - 137
American Oil and Gas Reporter - January 2015 - 138
American Oil and Gas Reporter - January 2015 - 139
American Oil and Gas Reporter - January 2015 - 140
American Oil and Gas Reporter - January 2015 - 141
American Oil and Gas Reporter - January 2015 - 142
American Oil and Gas Reporter - January 2015 - 143
American Oil and Gas Reporter - January 2015 - 144
American Oil and Gas Reporter - January 2015 - 145
American Oil and Gas Reporter - January 2015 - 146
American Oil and Gas Reporter - January 2015 - 147
American Oil and Gas Reporter - January 2015 - 148
American Oil and Gas Reporter - January 2015 - 149
American Oil and Gas Reporter - January 2015 - 150
American Oil and Gas Reporter - January 2015 - 151
American Oil and Gas Reporter - January 2015 - 152
American Oil and Gas Reporter - January 2015 - 153
American Oil and Gas Reporter - January 2015 - 154
American Oil and Gas Reporter - January 2015 - 155
American Oil and Gas Reporter - January 2015 - 156
American Oil and Gas Reporter - January 2015 - 157
American Oil and Gas Reporter - January 2015 - 158
American Oil and Gas Reporter - January 2015 - 159
American Oil and Gas Reporter - January 2015 - 160
American Oil and Gas Reporter - January 2015 - 161
American Oil and Gas Reporter - January 2015 - 162
American Oil and Gas Reporter - January 2015 - 163
American Oil and Gas Reporter - January 2015 - 164
American Oil and Gas Reporter - January 2015 - 165
American Oil and Gas Reporter - January 2015 - 166
American Oil and Gas Reporter - January 2015 - 167
American Oil and Gas Reporter - January 2015 - 168
American Oil and Gas Reporter - January 2015 - 169
American Oil and Gas Reporter - January 2015 - 170
American Oil and Gas Reporter - January 2015 - 171
American Oil and Gas Reporter - January 2015 - 172
American Oil and Gas Reporter - January 2015 - 173
American Oil and Gas Reporter - January 2015 - 174
American Oil and Gas Reporter - January 2015 - 175
American Oil and Gas Reporter - January 2015 - 176
American Oil and Gas Reporter - January 2015 - 177
American Oil and Gas Reporter - January 2015 - 178
American Oil and Gas Reporter - January 2015 - 179
American Oil and Gas Reporter - January 2015 - 180
American Oil and Gas Reporter - January 2015 - 181
American Oil and Gas Reporter - January 2015 - 182
American Oil and Gas Reporter - January 2015 - 183
American Oil and Gas Reporter - January 2015 - 184
American Oil and Gas Reporter - January 2015 - 185
American Oil and Gas Reporter - January 2015 - 186
American Oil and Gas Reporter - January 2015 - 187
American Oil and Gas Reporter - January 2015 - 188
American Oil and Gas Reporter - January 2015 - 189
American Oil and Gas Reporter - January 2015 - 190
American Oil and Gas Reporter - January 2015 - 191
American Oil and Gas Reporter - January 2015 - 192
American Oil and Gas Reporter - January 2015 - 193
American Oil and Gas Reporter - January 2015 - 194
American Oil and Gas Reporter - January 2015 - 195
American Oil and Gas Reporter - January 2015 - 196
American Oil and Gas Reporter - January 2015 - 197
American Oil and Gas Reporter - January 2015 - 198
American Oil and Gas Reporter - January 2015 - 199
American Oil and Gas Reporter - January 2015 - 200
American Oil and Gas Reporter - January 2015 - 201
American Oil and Gas Reporter - January 2015 - 202
American Oil and Gas Reporter - January 2015 - 203
American Oil and Gas Reporter - January 2015 - 204
American Oil and Gas Reporter - January 2015 - 205
American Oil and Gas Reporter - January 2015 - 206
American Oil and Gas Reporter - January 2015 - 207
American Oil and Gas Reporter - January 2015 - 208
American Oil and Gas Reporter - January 2015 - 209
American Oil and Gas Reporter - January 2015 - 210
American Oil and Gas Reporter - January 2015 - 211
American Oil and Gas Reporter - January 2015 - 212
American Oil and Gas Reporter - January 2015 - 213
American Oil and Gas Reporter - January 2015 - 214
American Oil and Gas Reporter - January 2015 - 215
American Oil and Gas Reporter - January 2015 - 216
American Oil and Gas Reporter - January 2015 - 217
American Oil and Gas Reporter - January 2015 - 218
American Oil and Gas Reporter - January 2015 - 219
American Oil and Gas Reporter - January 2015 - 220
American Oil and Gas Reporter - January 2015 - 221
American Oil and Gas Reporter - January 2015 - 222
American Oil and Gas Reporter - January 2015 - 223
American Oil and Gas Reporter - January 2015 - 224
American Oil and Gas Reporter - January 2015 - 225
American Oil and Gas Reporter - January 2015 - 226
American Oil and Gas Reporter - January 2015 - 227
American Oil and Gas Reporter - January 2015 - 228
American Oil and Gas Reporter - January 2015 - 229
American Oil and Gas Reporter - January 2015 - 230
American Oil and Gas Reporter - January 2015 - 231
American Oil and Gas Reporter - January 2015 - 232
American Oil and Gas Reporter - January 2015 - 233
American Oil and Gas Reporter - January 2015 - 234
American Oil and Gas Reporter - January 2015 - 235
American Oil and Gas Reporter - January 2015 - 236
American Oil and Gas Reporter - January 2015 - 237
American Oil and Gas Reporter - January 2015 - 238
American Oil and Gas Reporter - January 2015 - 239
American Oil and Gas Reporter - January 2015 - 240
American Oil and Gas Reporter - January 2015 - 241
American Oil and Gas Reporter - January 2015 - 242
American Oil and Gas Reporter - January 2015 - Cover3
American Oil and Gas Reporter - January 2015 - Cover4
http://staging.nxtbook.com/nxtbooks/aogr/201702/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201701/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201612/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201611/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201610/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/pbios2016_programguide/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201609/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201608/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201607/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201606/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201605/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201604/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201603/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201602/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201601/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201512/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201511/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201510/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201509/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201508/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201507/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201506/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201505/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201504/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201503/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201502/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201501/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201412/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201411/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201410/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201409/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/pbios2014_programguide/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201408/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201407/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201406/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201405/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201404/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201403/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201402/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201401/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201312/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201311/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201310/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201309/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201308/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201307/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201306/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201305/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201304/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201303/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201302/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201301/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201212/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201211/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201210/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201209/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/2012_pbios/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201208/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201207/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201206/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201205/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201204/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201203/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201202/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201201/stage.php
http://staging.nxtbook.com/nxtbooks/demo/aogr_clone/stage.php
http://staging.nxtbook.com/nxtbooks/aogr/201112/stage.php
https://www.nxtbookmedia.com