American Oil and Gas Reporter - January 2015 - 47

"The administration has made reducing
greenhouse gas emissions a cornerstone
of its second term," he noted. "Oil and
gas production is one of the targets. The
president has put forward a methane strategy that outlines broad parameters of
things it wants agencies to examine."
Kellogg said he had reason to believe
policymakers were discussing the regulatory pathways available to EPA for such
an initiative. "The idea that the industry
will not be impacted by forthcoming regulations simply is not in the cards," he
said. "The White House has given agencies
a political direction to do something. My
sense is that most operators are especially
concerned about regulations that target
existing operations, and the cost of possibly
having to undertake an intensive leak detection and repair program."
Supplementing potential methane regulations, Kellogg indicated, are EPA
efforts to lower the National Ambient
Air Quality Standard for ozone below
the current 75 parts per billion limit,
which may impact both new and existing
oil and natural gas operations. Volatile
organic compounds, which are a precursor
to ozone, are emitted from oil and natural
gas operations, he noted. Kellogg went
on to say that "while oil and natural gas
VOC emissions are small-and declining
because of voluntary measures and federal
regulations imposed in 2012-oil and natural gas operations could get caught up
in the ozone rule making implementation
plans if vast areas of the country are
brought into nonattainment."

He noted in mid-November that the
deadline also had passed for OSHA's
proposed rule regarding respiratory silica
protection, and said a final rule probably
was forthcoming. Meanwhile, Jordan
said, service companies also were hearing
rumors that the Federal Motor Carriers
Safety Administration might change truck
drivers' hours of service limitations. "It
is possible the oil field exemption could
be eliminated, which would be huge,"
he said. "I have not heard anything
specific from the FMCSA . . . but given
the environment we are in, it would not
surprise me."

He also said additional equipment requirements for those with commercial
driver's licenses were expanding to the
oil and gas industry. "The mandate for
electronic onboard recorders is coming
during the next couple years for all CDLs,
and is going to make its way into the oil
field," Jordan predicted.
With those issues and others, he said,
industry advocates knew new standards
were coming, but did not know when.
"We are in this limbo phase, waiting on
things we know are coming to slip under
the door at midnight," Jordan characterized.
Ì

Waiting In Limbo
During IPAA's Environment & Safety
Committee session, Kenny Jordan, executive vice president of the Association of
Energy Service Companies, commented
that the likelihood of new health and
safety rules offered another source of
regulatory uncertainty. He recounted how
OSHA had requested extensive data for
a process safety management rule, but
had yet to issue a specific proposal.

Coming In February
AOGR's February issue spotlights
one independent's new deepwater
field development projects, including
one field that commenced production
from a truss spar facility in late 2014
and other sanctioned project that is
scheduled to begin development
drilling in 2015. Guest authors also
evaluate the latest technologies for
subsurface imaging and reservoir
evaluation.
JANUARY 2015 47
American Oil and Gas Reporter - January 2015

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