American Oil and Gas Reporter - February 2016 - 78

to achieve larger air quality goals," the
association comments. "In this situation,
Texans in particular are impacted by the
success or failure of the oil and gas
industry more than citizens of any other
state."
Flexibility Preferred
Along with questioning the speed of
the compliance timeline for the agency's
proposed rules on methane and volatile
organic compounds, TIPRO recommends
that the EPA embrace flexibility instead
of dictating specific technologies. Leak
detection and reporting requirements
(LDAR) in the draft rules mandate optical
gas imaging tools to confirm that a leaking
component has been repaired, but other
methods exist, TIPRO indicates, and superior technologies are likely to appear
in the future.
LDAR should be consistent and not
duplicate current state programs, says
the association, adding that it is impractical
to quantify the amount of methane a rule
may save. An LDAR program should not
be based on component count or percentage of components leaking.
Meanwhile, EPA incorrectly assumes
that reduced emission completions on oil
wells are the same as reduced emission
completions on natural gas wells, TIPRO

states. Implementing reduced emission
completions or combustion devices or
flares at oil wells will be redundant
because operators already use them at a
majority of wells, the association says.
"EPA's proposal to require pneumatic
pumps fails to consider the true difficulty
and cost of transferring captured gas to
an existing combustion device," TIPRO
says. "Pneumatic pumps lack cost efficiency when considering the relatively
small volume of gas captured."
In an instance of approval, meanwhile,
TIPRO applauds EPA for continuing to
refrain from proposing federal standards
on liquids unloading emissions, which,
the association notes, can vary widely by
well type and region.
Intended Purpose
Among their other interim charges
this year, state lawmakers also will consider how the Texas Emission Reduction
Plan (TERP) can help mitigate the downside of any new EPA rules, says Lindsey
Miller, TIPRO's director of government
and regulatory affairs. The Senate Natural
Resources and Economic Development
Committee specifically is examining the
use of TERP funds, including reducing
air emissions from mobile sources in response to changes in ozone standards.

TERP provides financial incentives to
eligible individuals, businesses or local
governments to reduce emissions from
polluting vehicles and equipment, Miller
explains. TIPRO generally supports directing TERP funds toward transportation-related projects that may help the
state meet new ozone standards, she
relates, but the association opposes a
broader diversion of funds from initiatives
to meet new federal standards handed
down by the EPA on Oct. 1, 2015.
House and Senate bills that called for
such a shift were unsuccessful in 2015
during the 84th Legislature, she reports.
"With the ever-growing list of onerous
proposals from the EPA and regulatory
uncertainty facing our state, we must
protect the funds and ensure they are utilized for their intended purpose," Longanecker adds.
State officials already are contesting
new ozone standards, he points out. On
Dec. 23, Texas Attorney General Ken Paxton
filed a lawsuit on behalf of the state and the
Texas Commission on Environmental Quality against EPA over the agency's 2015
changes to the National Ambient Air Quality
Standard governing ozone.
In the lawsuit, Paxton contends EPA's
new standards may impose a serious financial burden on the Texas economy

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American Oil and Gas Reporter - February 2016

Table of Contents for the Digital Edition of American Oil and Gas Reporter - February 2016

Contents
American Oil and Gas Reporter - February 2016 - Cover1
American Oil and Gas Reporter - February 2016 - Cover2
American Oil and Gas Reporter - February 2016 - Contents
American Oil and Gas Reporter - February 2016 - 4
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American Oil and Gas Reporter - February 2016 - Cover3
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