American Oil and Gas Reporter - May 2015 - 143

rule because, for the first time, a storage
vessel installed in parallel with another
vessel may become subject to the standards
based on the emissions of a vessel to which
is it connected," the association states.
The TxOGA petition also says both
of those "in parallel" provisions change
the rule's applicability, yet they were
never proposed by EPA, and so did not
receive public comment during consideration of the NSPS. The changes are of
central relevance to the rule because they
significantly expand its applicability and
impose substantial additional costs by
requiring operators to determine on a
case-by-case basis whether any particular
set of storage vessels is subject to the
rule, the association says.
"Emission control requirements are

based on the emissions from each (affected
storage vessel). Because there are multiple
configurations for installation and because
any given installation may be operated
in different configurations, the rule language has created significant confusion,
potentially exposing companies to enforcement and leading to the need for
case-by-case interpretations from EPA
and delegated state permitting authorities.
If EPA had proposed these changes, these
concerns certainly would have been
raised," TxOGA says.
EPA should conduct a rule making to
remove the "in parallel" provisions and
stay the regulations during that process,
TxOGA urges, arguing the delay is appropriate and necessary because applicability was expanded without providing

proper notice.
"The applicability expansion will impose significant costs on TxOGA's members, both in terms of potential control
costs and administrative costs to determine
whether particular configurations were
intended to be covered by the new regulatory language," TxOGA's petition states.
"TxOGA members already have encountered state regulators seeking to enforce
the improperly promulgated new language
for previously unregulated vessels, demonstrating that the rule language is having
immediate impacts on regulated entities.
Finally, there is no question that TxOGA
is likely to succeed in any challenge to
the rule in this regard because there is no
question that EPA failed to meet its rulemaking obligations."
Ì

Groups Question Lower Ozone Limit
WASHINGTON-A "false peak" is
the mountaineering term for a point on
the mountain that a climber perceives to
be the top until he reaches it. The experience of striving to reach that false peak-
only to learn the summit remains unattained-carries with it a reputation for
dashing many a climber's hopes.
Areas of the country that have been
striving to meet ozone limits the U.S. Environmental Protection Agency has set
under the Clean Air Act may experience
that same psychological letdown as EPA
moves to tighten a standard it established
less than a decade ago. The agency is
proposing to lower the limit for ozone to
a range between 70 parts per billion and
65 ppb, although it also has asked for
comments on a limit as low as 60 ppb
(AOGR, January 2015, pg. 36).
A number of oil and gas associations,
as well as groups representing manufacturers and other sectors of the economy,
are urging EPA to retain its existing standards while voicing concerns about the
rationale for new limits and their likely
harm to the nation's economy.
American Petroleum Institute Senior
Director of Regulatory and Scientific Affairs Howard Feldman observes that
EPA's current 75 ppb ozone standard
has been in place only since 2008, and
has not been fully implemented. "We
question the wisdom and the motivation
behind burdening our nation's still recovering economy and the American consumer with more costly regulations before
the current regulations have been given
time to work," Feldman states. "This rule
could be the costliest regulation ever imposed on the American public."
The Independent Petroleum Associa-

tion of America, in comments filed in
conjunction with a number of other industry groups, contends the proposed
standards are unlikely to offer the results
EPA claims to seek, since even EPA predicts that the most populated nonattainment
areas-where air quality improvements
offer the greatest health impacts-will fail
to meet the proposed standard. Groups
signing onto IPAA's comments include
the American Association of Professional
Landmen, The American Exploration and
Production Council, Association of Energy
Service Companies, International Association of Drilling Contractors, International Association of Geophysical Contractors, National Stripper Well Association, National Association of Royalty
Owners, Petroleum Equipment Suppliers
Association, and 41 state and regional
independent producer associations.
How Low?
Comments from API, as well as groups
including IPAA and the New Mexico
Oil & Gas Association, cite findings in
an analysis by the National Economic
Research Associates Economic Consulting,
which was commissioned by the National
Association of Manufacturers. NAM notes
the NERA study determines that revising
the National Ambient Air Quality Standard
for ozone from 75 ppb to 65 ppb may:
* Reduce U.S. gross domestic product
by $140 billion a year and $1.7 trillion
from 2017 to 2040;
* Result in an average 1.4 million
fewer full-time job equivalents a year
through 2040; and
* Cost the average U.S. household
$830 a year in the form of lost consumption.

"The administration's push for a more
restrictive ozone standard is yet another
painful example of the need for comprehensive regulatory reform," holds NAM
Senior Vice President of Policy and Government Relations Aric Newhouse. "Further tightening a standard that so many
parts of our nation still can't meet creates
an undue strain on our economic recovery.
Rather than adding to the regulatory pains
already felt so acutely by our nation's
manufacturing sector, the administration
should focus on allowing existing standards to be fully implemented."
Irrational Estimates
EPA initially proposed the tougher
NAAQS limit for ozone in 2011, NAM
notes, but President Barack Obama halted
it because of what he called "regulatory
burdens and uncertainty."
IPAA recalls the regulatory impact
analysis EPA issued with its 2011 proposal
estimated a median net benefit of $700
million for a 65 ppb standard, but when
it revived the proposal in 2014, the agency
unveiled a very different cost/benefit
analysis. In fact, IPAA points out, some
of the estimates EPA released in 2011
calculated zero net benefits from the proposal. "But in 2014, the EPA . . . claims
net benefits of a lower ozone standard as
high as $23 billion: a 3,100 percent increase in net benefits for the exact same
standard," the association observes.
NMOGA also highlights the relative
rosiness of EPA's newest projections
versus its former ones. "Comparing the
benefits claimed by EPA for the currently
proposed lowered standard with benefits
discussed for the 2008 ozone standard
and its subsequent reconsideration, EPA
MAY 2015 143



American Oil and Gas Reporter - May 2015

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

Contents
American Oil and Gas Reporter - May 2015 - Cover1
American Oil and Gas Reporter - May 2015 - Cover2
American Oil and Gas Reporter - May 2015 - Contents
American Oil and Gas Reporter - May 2015 - 4
American Oil and Gas Reporter - May 2015 - 5
American Oil and Gas Reporter - May 2015 - 6
American Oil and Gas Reporter - May 2015 - 7
American Oil and Gas Reporter - May 2015 - 8
American Oil and Gas Reporter - May 2015 - 9
American Oil and Gas Reporter - May 2015 - 10
American Oil and Gas Reporter - May 2015 - 11
American Oil and Gas Reporter - May 2015 - 12
American Oil and Gas Reporter - May 2015 - 13
American Oil and Gas Reporter - May 2015 - 14
American Oil and Gas Reporter - May 2015 - 15
American Oil and Gas Reporter - May 2015 - 16
American Oil and Gas Reporter - May 2015 - 17
American Oil and Gas Reporter - May 2015 - 18
American Oil and Gas Reporter - May 2015 - 19
American Oil and Gas Reporter - May 2015 - 20
American Oil and Gas Reporter - May 2015 - 21
American Oil and Gas Reporter - May 2015 - 22
American Oil and Gas Reporter - May 2015 - 23
American Oil and Gas Reporter - May 2015 - 24
American Oil and Gas Reporter - May 2015 - 25
American Oil and Gas Reporter - May 2015 - 26
American Oil and Gas Reporter - May 2015 - 27
American Oil and Gas Reporter - May 2015 - 28
American Oil and Gas Reporter - May 2015 - 29
American Oil and Gas Reporter - May 2015 - 30
American Oil and Gas Reporter - May 2015 - 31
American Oil and Gas Reporter - May 2015 - 32
American Oil and Gas Reporter - May 2015 - 33
American Oil and Gas Reporter - May 2015 - 34
American Oil and Gas Reporter - May 2015 - 35
American Oil and Gas Reporter - May 2015 - 36
American Oil and Gas Reporter - May 2015 - 37
American Oil and Gas Reporter - May 2015 - 38
American Oil and Gas Reporter - May 2015 - 39
American Oil and Gas Reporter - May 2015 - 40
American Oil and Gas Reporter - May 2015 - 41
American Oil and Gas Reporter - May 2015 - 42
American Oil and Gas Reporter - May 2015 - 43
American Oil and Gas Reporter - May 2015 - 44
American Oil and Gas Reporter - May 2015 - 45
American Oil and Gas Reporter - May 2015 - 46
American Oil and Gas Reporter - May 2015 - 47
American Oil and Gas Reporter - May 2015 - 48
American Oil and Gas Reporter - May 2015 - 49
American Oil and Gas Reporter - May 2015 - 50
American Oil and Gas Reporter - May 2015 - 51
American Oil and Gas Reporter - May 2015 - 52
American Oil and Gas Reporter - May 2015 - 53
American Oil and Gas Reporter - May 2015 - 54
American Oil and Gas Reporter - May 2015 - 55
American Oil and Gas Reporter - May 2015 - 56
American Oil and Gas Reporter - May 2015 - 57
American Oil and Gas Reporter - May 2015 - 58
American Oil and Gas Reporter - May 2015 - 59
American Oil and Gas Reporter - May 2015 - 60
American Oil and Gas Reporter - May 2015 - 61
American Oil and Gas Reporter - May 2015 - 62
American Oil and Gas Reporter - May 2015 - 63
American Oil and Gas Reporter - May 2015 - 64
American Oil and Gas Reporter - May 2015 - 65
American Oil and Gas Reporter - May 2015 - 66
American Oil and Gas Reporter - May 2015 - 67
American Oil and Gas Reporter - May 2015 - 68
American Oil and Gas Reporter - May 2015 - 69
American Oil and Gas Reporter - May 2015 - 70
American Oil and Gas Reporter - May 2015 - 71
American Oil and Gas Reporter - May 2015 - 72
American Oil and Gas Reporter - May 2015 - 73
American Oil and Gas Reporter - May 2015 - 74
American Oil and Gas Reporter - May 2015 - 75
American Oil and Gas Reporter - May 2015 - 76
American Oil and Gas Reporter - May 2015 - 77
American Oil and Gas Reporter - May 2015 - 78
American Oil and Gas Reporter - May 2015 - 79
American Oil and Gas Reporter - May 2015 - 80
American Oil and Gas Reporter - May 2015 - 81
American Oil and Gas Reporter - May 2015 - 82
American Oil and Gas Reporter - May 2015 - 83
American Oil and Gas Reporter - May 2015 - 84
American Oil and Gas Reporter - May 2015 - 85
American Oil and Gas Reporter - May 2015 - 86
American Oil and Gas Reporter - May 2015 - 87
American Oil and Gas Reporter - May 2015 - 88
American Oil and Gas Reporter - May 2015 - 89
American Oil and Gas Reporter - May 2015 - 90
American Oil and Gas Reporter - May 2015 - 91
American Oil and Gas Reporter - May 2015 - 92
American Oil and Gas Reporter - May 2015 - 93
American Oil and Gas Reporter - May 2015 - 94
American Oil and Gas Reporter - May 2015 - 95
American Oil and Gas Reporter - May 2015 - 96
American Oil and Gas Reporter - May 2015 - 97
American Oil and Gas Reporter - May 2015 - 98
American Oil and Gas Reporter - May 2015 - 99
American Oil and Gas Reporter - May 2015 - 100
American Oil and Gas Reporter - May 2015 - 101
American Oil and Gas Reporter - May 2015 - 102
American Oil and Gas Reporter - May 2015 - 103
American Oil and Gas Reporter - May 2015 - 104
American Oil and Gas Reporter - May 2015 - 105
American Oil and Gas Reporter - May 2015 - 106
American Oil and Gas Reporter - May 2015 - 107
American Oil and Gas Reporter - May 2015 - 108
American Oil and Gas Reporter - May 2015 - 109
American Oil and Gas Reporter - May 2015 - 110
American Oil and Gas Reporter - May 2015 - 111
American Oil and Gas Reporter - May 2015 - 112
American Oil and Gas Reporter - May 2015 - 113
American Oil and Gas Reporter - May 2015 - 114
American Oil and Gas Reporter - May 2015 - 115
American Oil and Gas Reporter - May 2015 - 116
American Oil and Gas Reporter - May 2015 - 117
American Oil and Gas Reporter - May 2015 - 118
American Oil and Gas Reporter - May 2015 - 119
American Oil and Gas Reporter - May 2015 - 120
American Oil and Gas Reporter - May 2015 - 121
American Oil and Gas Reporter - May 2015 - 122
American Oil and Gas Reporter - May 2015 - 123
American Oil and Gas Reporter - May 2015 - 124
American Oil and Gas Reporter - May 2015 - 125
American Oil and Gas Reporter - May 2015 - 126
American Oil and Gas Reporter - May 2015 - 127
American Oil and Gas Reporter - May 2015 - 128
American Oil and Gas Reporter - May 2015 - 129
American Oil and Gas Reporter - May 2015 - 130
American Oil and Gas Reporter - May 2015 - 131
American Oil and Gas Reporter - May 2015 - 132
American Oil and Gas Reporter - May 2015 - 133
American Oil and Gas Reporter - May 2015 - 134
American Oil and Gas Reporter - May 2015 - 135
American Oil and Gas Reporter - May 2015 - 136
American Oil and Gas Reporter - May 2015 - 137
American Oil and Gas Reporter - May 2015 - 138
American Oil and Gas Reporter - May 2015 - 139
American Oil and Gas Reporter - May 2015 - 140
American Oil and Gas Reporter - May 2015 - 141
American Oil and Gas Reporter - May 2015 - 142
American Oil and Gas Reporter - May 2015 - 143
American Oil and Gas Reporter - May 2015 - 144
American Oil and Gas Reporter - May 2015 - 145
American Oil and Gas Reporter - May 2015 - 146
American Oil and Gas Reporter - May 2015 - 147
American Oil and Gas Reporter - May 2015 - 148
American Oil and Gas Reporter - May 2015 - 149
American Oil and Gas Reporter - May 2015 - 150
American Oil and Gas Reporter - May 2015 - 151
American Oil and Gas Reporter - May 2015 - 152
American Oil and Gas Reporter - May 2015 - 153
American Oil and Gas Reporter - May 2015 - 154
American Oil and Gas Reporter - May 2015 - 155
American Oil and Gas Reporter - May 2015 - 156
American Oil and Gas Reporter - May 2015 - 157
American Oil and Gas Reporter - May 2015 - 158
American Oil and Gas Reporter - May 2015 - 159
American Oil and Gas Reporter - May 2015 - 160
American Oil and Gas Reporter - May 2015 - 161
American Oil and Gas Reporter - May 2015 - 162
American Oil and Gas Reporter - May 2015 - Cover3
American Oil and Gas Reporter - May 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