American Oil and Gas Reporter - August 2015 - 153

She said IPAA submitted an extension
request, but was told by USFWS that it
was not likely to be granted because of
time pressures.

EPA Regulations
Also on the horizon, advised IPAA
Vice President of Government Relations
Lee Fuller, are possible direct federal regulation of methane emissions and a rule
making on aggregating facilities under the
Clean Air Act.
As a follow-on to its Climate Action
Strategy to Reduce Methane Emissions released in March 2014, the administration
in January announced its intent to lower
methane emissions from the oil and gas
sector by 40-45 percent from 2012 levels
by 2025 (AOGR, February 2015, pg. 46).
Those proposed regulations were sent
to OMB on June 23, Fuller reported,
along with a proposed rule on aggregation.
"We don't know what those are going to
look like, but they could be adverse," he
advised.
Working with the American Petroleum
Institute "to present a common face,"
Fuller said IPAA was pressing EPA as

well as the Small Business Administration
for cost effective regulations that would
build on rules for volatile organic compounds-primarily the New Source Performance Standards Subpart OOOO-that
might meet the administration's objectives
"without going down the path the environmentalists want, which is direct methane
regulations that would bring in existing
sources that otherwise wouldn't get captured."
He said SBA was important because it
could conduct a "small business advocacy review" for regulations that have a significant effect on small businesses. "We
pressed SBA to do a small business advocacy review on the methane package (as
part of an attempt) to keep small wells out
of that regulatory package," Fuller revealed.
He noted aggregation was significant
because numerous smaller facilities and/or
wells might come under CAA permitting
requirements if their emissions were aggregated rather than measured separately.
Rulings by U.S. courts of appeal for the
6th and D.C. circuits in 2012 and 2013
"have tempered EPA's ability to aggregate," Fuller reflected. "So now it is try-

ing to come back with a formal rule
making."
To a degree, Fuller continued, the
methane issue may interface with EPA's
deadline to establish a new National Ambient Air Quality Standard for ground-level ozone. The agency has proposed to lower its ozone NAAQS from 75 parts per billion to 65-70 ppb, although Fuller observed,
"It also has sought comments on 60 ppb."
He remarked that the National Association of Manufacturers "has been the
most vigorous force" rallying opposition
to that, sponsoring studies and coordinating various states and industries.
"We have weighed in on this issue to
make the point that by EPA's own admission, areas that don't meet the current
ozone standard won't meet a new one, either," Fuller said. "That means there will
be no health benefits for all those communities from a lower standard because it
doesn't change the regulatory requirements
in those areas. The way the CAA is structured, (communities attempt to) iteratively reduce emissions every five years.
If they can't reach 75 ppb, they keep doing the same thing."
❒

IPAA Midyear Meeting

New Image Effort Joining Old Priorities
By Bill Campbell

SANTA FE, N.M.-The Independent
Petroleum Association of America's top
priorities remain lifting the U.S. ban on
crude oil exports and preserving the industry's federal income tax deductions, participants in the association's midyear
meeting, June 24-26 at the Eldorado Hotel in Santa Fe, were advised.
But growing in importance, said IPAA
President and Chief Executive Officer Barry Russell, are efforts to recast public debate from focusing on fossil fuels' drawbacks to their benefits.
Also on the horizon, according to a report delivered during the association's Natural Gas Committee session, may be an attempt by the U.S. Department of Transportation to push pipeline regulation closer to the wellhead.
During the June 26 general session,
Russell assured members IPAA remained
focused on traditional legislative and regulatory issues such as hydraulic fracturing,
environmental regulations, the crude oil
export ban, and taxes. But concurrent with
that, he said, IPAA hopes to fashion a fresh
response to the organized attack on oil and
gas by taking a cue from Alex Epstein's
book, The Moral Case for Fossil Fuels.

Heretofore, Russell observed, IPAA
has emphasized the economic benefits, taxes and jobs generated by the oil and gas
industry. "But we also want to make

In addition to its Capitol Hill advocacy, the
Independent Petroleum Association of
America has begun to emphasize the
moral imperative of utilizing affordable
and abundant energy resources to improve conditions for less privileged people worldwide, President and Chief Executive Officer Barry Russell tells members
during the association's midyear meeting,
June 24-26 in Santa Fe, N.M.

people begin to recognize the benefits derived from plentiful, affordable energy, especially for lower-income people," he declared.
He noted that 1 billion people worldwide had no electricity, while nearly another 1 billion lacked access to clean water. As an example of what that means in
human terms, Russell pointed out that in
undeveloped countries that had only intermittent electrical service at best, thousands
of infants died because there was no reliable source of energy to run incubators.
He said IPAA has added a section to its
website "to address this topic and provide
a resource for those interested in the extensive contributions of fossil fuels to
worldwide living standards."
Hand-in-hand with that, Russell went
on, IPAA already has launched www.divestmentfacts.com, in response to the divestment issue.
Anti-fossil-fuel activists have been
organizing student demonstrations aimed
at forcing universities to divest their endowment portfolios of all fossil fuel investments. Russell said IPAA's response was
to explain, "These endowments generate
income that primarily provides financial
aid for lower-income students. When you
remove a broad category of investments,
AUGUST 2015 153

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