American Oil and Gas Reporter - September 2016 - 99

aspects of what a pumper encounters.
We had a lot of good feedback. That is
why we are going to hold one in Indiana,
too."
In fact, he says, the only qualm attendees often voiced in their evaluations
was a desire for more time to dwell on
the subject. "Some people said it went
too quickly," Hoy acknowledges. "Especially if people are hearing something
for the first time, it can be difficult for
them to grasp it all at once."
State And Federal Rules
As Hoy considers the public policy
challenges facing Indiana's industry, he
mentions state and federal regulatory
challenges.
From Indianapolis, he cites a rewrite
of the state's oil and gas rules by the Division of Oil and Gas within the Indiana
Department of Natural Resources. The
process has been under way for more
than two years and the proposal has been
unveiled. "The comment period and a
public hearing are coming soon," he says.
"We have had a chance to see the rewrites.
Some people have some issues with them,
and rightfully so. A link to comment can
be found on the DNR website."
One reason for those complaints, he
says, stems from the extent to which the
new rules ignore a mandate from Indiana
Governor Mike Pence that state agencies'
regulatory initiatives not add to businesses'
financial burden. Even so, Hoy estimates,
some aspects of the proposal are certain
to increase costs.
"A couple of the biggest provisions
deal with operators' obligations within a
100-year floodplain and pit liner requirements," he relates. "Nothing (in the proposal) is going to bring costs down. Any
time government gets more involved, it
always increases costs. Complying with
stricter rules will add to operators' financial
burdens. Of course, they should comply
with all the rules, but it is that much
harder to swallow in a down market."
As for regulatory initiatives emanating
from Washington, Hoy points toward the
U.S. Environmental Protection Agency's
moves this spring that include final standards under the Clean Air Act's New
Source Performance Standards that are
intended to cut emissions of methane,
volatile organic compounds and toxic air
emissions from new, modified and reconstructed oil and gas industry sources,
as well the agency's accompanying request
for information seeking data that may be
used to develop nationwide regulations
on the same emissions from existing
sources (AOGR, June 2016, pg. 34).
"In addition to finalizing NSPS Subpart
OOOOa, the Obama administration now

is considering all existing wells and facilities," Hoy reflects. "We are involved
with 18 other associations in writing a
rebuttal."
As for the regulations' implications
for Indiana producers, he is blunt. "It
would put a lot of stripper well operators
out of business," he predicts.
Despite such frustrations, Hoy says
INOGA continues to work with EPA where
it can, and offers the example of a meeting
in which some representatives of the association and area operators met with EPA
Region V staff to discuss the agency's
plans for area wetlands. The meeting
seemed to be worthwhile, he says.
"We have been invited back for the
next one," he says. "Hopefully, we can
start getting some communications that
make for more common-sense decisions."
An example Hoy cites in which he
hopes such dialogue will bear fruit deals
with EPA's attempts to set up spill containment equipment trailers. "I think if
an operator fails to contain a spill immediately, EPA will simply take over," he
details. "When that happens, it is out of
(the operator's) hands. EPA has a tendency
to go full bore without any concern about
how much you will have to pay later. We
are hoping to discuss that with EPA staff."
Annual Meeting
Hoy is scheduled to pass the INOGA
president's gavel to Kyle Kingston with
Rex Energy at the group's 2016 annual
meeting, Oct. 6 in Evansville. Although
he is looking forward to that moment, Hoy
says he also is looking forward to hearing
the presentations and spending time with
his industry friends and colleagues.
"The talks offer a chance to learn
something; we are kind of opening it to a
call for interesting papers," he describes.
"I also really enjoy seeing people and
getting a feel for what is on their minds."
As for any lessons Hoy may have
learned from his tenure as the group's
top officer, he reflects that the position
has helped him appreciate the enormity
of the task before INOGA. That seems
especially true of an all-volunteer organization, he reflects. "We cannot do it
enough justice," he describes. "I understand
how much hard work there is to be done,
and how little time there is for any of us
to do it. It is tough trying to stay up-todate on all the EPA's rules and regulations,
but no one pays us to do that."
❒

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SEPTEMBER 2016 99

American Oil and Gas Reporter - September 2016

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