American Oil and Gas Reporter - August 2016 - 90

ConventionSection: Petroleum Association of Wyoming

Wyoming Continues Coping
With Federal Overreach
By Dan Holder
CASPER, WY.-With more than 48
percent of its land owned by the United
States, Wyoming could be seen as an excellent laboratory for experiments on federal/state regulations, judges Randy Harris,
chairman of the Petroleum Association
of Wyoming.
"Wyoming is a different animal than
a lot of other states, in the sense that its
landscape is made up of federal, state
and private lands," says Harris, director
of corporate development for Denverbased Black Hills Exploration & Production Inc. "There are so many more
things that a company has to deal with in
Wyoming to drill a well compared with,
say, North Dakota or Texas."
As he prepares for PAW's annual convention and trade show, set for Aug. 1517 at the Parkway Plaza Hotel in Casper,
Harris says Wyoming offers a great perspective in terms of which level of government is best suited to regulate and

oversee oil and gas operations.
"There always is proactive attention
coming from the Environmental Protection
Agency, Bureau of Land Management,
and other federal agencies," he describes.
"If Wyoming can continue to show it is
taking care of business, and is handling
these issues appropriately, that will minimize federal overreach."
BLM's plans to revise its oil and gas
measurement and accountability policies
are another example of minor federal
changes that add to major financial burdens
for producers, PAW Vice President John
Robitaille says.
"The new rules are going to require
new equipment and new ways of record
keeping," he describes. "It may not make
sense to continue to produce a stripper
well; an operator may have to plug that
well prematurely. Perhaps required expenses even are disincentivizing new
wells. In Wyoming, where the federal
government owns two-thirds of the minerals, that is a very big problem."

PAW Annual Meeting - Casper, Wy.
Tuesday, Aug. 16
7 a.m. Continental Breakfast, Parkway Plaza
Hotel & Convention Center Mallway
7 a.m. Trade Show Opens
8-11:30 a.m. PAW Committee Meetings
Government, Legal, Taxation and Membership Committees, Wyoming Room
Environmental/E&P, Transportation and
Safety Committee, Ballroom A
Public Lands Committee, Ballrooms B&C
11:30 a.m. Buffet Luncheon, Mardi Gras/Natrona
1 p.m. PAW PAC Golf Tournament, Casper
Country Club
6 p.m. Chairman's Reception and Dinner,
Parkway Plaza Ballroom

Wednesday, Aug. 17
7 a.m. Continental Breakfast, Parkway Plaza
Mallway
7 a.m. Trade Show Opens
8-10 a.m. Seminars
Wyoming Department of Revenue and
Wyoming Department of Audit: Excise
Tax Division Manager Terri Lucero, Audit
Director Jeff Vogel, Mineral Audit Division
90 THE AMERICAN OIL & GAS REPORTER

Administrator Steve Dilsaver
Environmental/E&P and Public Lands Committee: Wyoming Oil & Gas Conservation
Commission Supervisor Mark Watson,
Bureau of Land Management State Director
Mary Jo Rugwell, Wyoming Governor's
Natural Resource Policy Director Jerimiah
Rieman, U.S. Fish & Wildlife Service
Field Supervisor Tyler Abbott, Office of
State Lands and Investments TBD,
Wyoming Wildlife and Natural Resource
Trust Executive Director Bob Budd
10 a.m.-Noon General Session
PAW Chairman's Report
Election of PAW Board of Directors
Report from Congressional Delegation: Senator Mike Enzi, Senator John Barrasso,
Congresswoman Cynthia Lummis
"The Man-Made Climate Change Debate,"
Don Day Jr., President/Meteorologist,
DayWeather Inc.
Noon-1 p.m. Keynote Luncheon
"How Clean Power Plan Affects Oil &
Gas Industry," Pat Day, Holland & Hart
1:15 p.m. PAW Board of Directors Meeting

However, Robitaille notes, in one regard, Wyoming's federal challenge mirrors
that of every other state: the cumulative
impacts of federal regulations.
"If you look at only one of the regulations coming out of Washington, it doesn't
appear to be a significant problem. But,
if you look at all those regulations cumulatively, you start to see a real problem.
We have multiple state and federal regulations covering the same things. There
is a massive expense because of double
regulating, and it is unnecessary in a lot
of situations."
Onshore Orders
According to BLM, its regulations for
oil and gas operations on federal and
Indian lands have not been updated since
1989 and don't reflect modern standards.
The agency wants to rewrite Onshore
Order No. 3, which establishes standards
for measurement and production accountability, Onshore Order No. 4, which sets
measurement standards for crude oil production, and Order No. 5, which covers
natural gas measurements.
In its comments on the proposed revisions, PAW warns that the federal government's projections on regulatory costs
are understated, Robitaille says.
"The government's ploy is to submit
Onshore Order No. 3. Individually, that
rule does not cause much pain. And then,
it will submit Order No. 4. Again, individually it will not cause much pain.
Then, it will submit Order No. 5. When
you look at all those together, that is a
tremendous amount of pain," he says.
In addition to costs associated with the
revised onshore orders, Robitaille points
to other federal and state requirements on
the horizon-including those affecting bonding, air quality and tank emissions-that
will incur additional-record keeping and
technology costs on operators.
"All these things add to the burden on
a particular well," he assesses. "When
that well cannot pay off all those things,
it goes away. If enough of those wells go
away, we have a significant problem because we lose the benefits from those
wells."

American Oil and Gas Reporter - August 2016

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