American Oil and Gas Reporter - January 2015 - 216

The Alliance's Fight the Overreach
Fund will provide the means necessary to
effectively push back on several hostile
policies we anticipate will come at us
during the last two lame-duck years of the
Obama administration. The Western Energy
Alliance will use the fund for three main
efforts: public outreach, legal challenges
and coalition building. By educating the
public and policymakers, we hope to stop
or overturn some of the overregulation,
such as overly restrictive species listings,
federal fracturing regulation, and public
land closures.
Yes, the association's member com-

panies are confronting Pikes Peak-type
challenges. We believe that a nimble,
dedicated staff, committed members and
cooperation with our sister extractive industries is the pathway forward. Our associates in agricultural communities and
outdoor recreation industries, which also
depend on public lands access, are willing
partners with us in advancing reasoned
policies relating to multiple use.
Oil and gas no longer is the realm of
television villains. Our industry is a technology player, with skilled scientists and
disciplined technicians advancing extractive
techniques while reducing our footprint,

Association of Energy
Service Companies
DANIEL COMALANDER
Asset Manager
Key Energy Services Inc.
Odessa, Tx.

FROM THE PRESIDENT
The Association of Energy Service
Companies was founded in the Permian
Basin of Texas in 1956. Then it was
known as the Association of Oilwell Servicing Contractors. A group of rig contractors saw a need for having a unified
voice to deal with workplace safety, develop common work practices, and have
some weight when dealing with government regulation. Over the past 58 years,
AESC has grown to 18 chapters covering
38 states. Our membership has grown to
800 member companies that employ
350,000 workers.
The past year has been eventful, not
only for the association, but for the entire
oil and gas industry. The association dealt
with numerous issues throughout the year
and anticipates a continuation of many
of those issues in 2015.
The Texas Railroad Commission proposed amendments to 16 Texas Administrative Code T 3.9 and 3.46, relating to
disposal wells and fluid injection into
productive reservoirs. The amendments
were to incorporate requirements related
to seismic events for disposal wells.
The RRC then requested comments
from the public. According to the Railroad
Commission memo, 36 comments were
submitted, including three against hydraulic fracturing and one against fossil
fuel. AESC joined with four associations
to address the proposed amendments.
Our industry supports the Railroad Com-

mission and its authority to regulate disposal wells and fluid injection activity,
and we appreciated the opportunity to
give valuable input as directed from our
members.
AESC signed a letter of support with
the National Institute for Occupational
Safety and Health, which is working on
an antidote for hydrogen sulfide exposure.
Hydrogen sulfide is an extremely toxic
gas for which no treatment is available.
Workers in a variety of industries-most
notably the oil and gas industries-are exposed to hydrogen sulfide. Hydrogen sulfide is the second-leading cause of industrial worker deaths from gas inhalation,
after carbon monoxide. Workplace safety
always has been a priority of AESC and
its members.
As part of an AESC and Region VI
Occupational Safety & Health Administration agreement, the association held
its first training/orientation for OSHA
inspectors starting on Aug. 6. OSHA had
25 inspectors in attendance. On the first
day, classroom training was held; on the
second day, inspectors visited a North
Texas yard location to perform a service
rig-up overview/inspection. This is the
first event of this kind done with the cooperation of the oil and gas industry that
I know of, with a focus on well servicing.
AESC continued to be politically active
throughout the midterm elections. Its an-

216 THE AMERICAN OIL & GAS REPORTER

emissions, and impacts on the environment.
We are experts in mitigation, in restoration,
and most especially in delivering the raw
materials needed to maintain the lifestyle
and prosperity that is America.
I recall one old-timer saying at what
was then the Independent Petroleum Association of Mountain States' annual
meeting, "Oil and whisky have much in
common: They never have been priced
what they are worth." That generated
some laughs. For today I prefer this
simple truth, "If we want to live this
quality of life, someone has to dig a
hole."
Ì
nual Washington fly-in is conducted every
spring. AESC representatives from across
the United States meet in Washington
with numerous legislators and staff members.
Hours Of Service
The Federal Motor Carrier Safety Administration has changed the eligibility
rules for federal hours of service requirements. Operators of vehicles that haul
water and sand to fracture jobs no longer
are exempt under interpretation. Hours
spent waiting to unload now are counted
toward an operator's maximum number
of hours eligibility to safely operate a
motor vehicle.
To correct this issue, AESC continues
to support legislation introduced by Oklahoma Republicans, Congressman Markwayne Mullin and Senator James Inhofe.
Their bills specify that all commercial
motor vehicles used to transport supplies
to and from a natural gas or oil well site
are eligible under the oil-field hours of
service exemption.
AESC members are encouraged to
communicate support for these bills (HR
1097 and SB 1380) to their individual
lawmakers.
Also, AESC members share the desire
to protect all wildlife against extinction,
but believe that scientific data should
guide decisions that could reduce or
restrict the right to develop private land.
The association encourages its members
to do two things: voice support for legislation that would bring increased transparency to endangered species listing decisions, and advocate for considering the
economic consequences of a listing before
a decision is made.
Other Programs
OSHA is contemplating a rule that
would alter the silica exposure standard,
and would direct oil and gas companies
to adopt new and costly procedures.
AESC Executive Director Kenny Jordan

American Oil and Gas Reporter - January 2015

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