American Oil and Gas Reporter - August 2019 - 129

ConventionSection: Kansas Independent Oil & Gas Association
has been revealed the pressure data submitted for the Class I wells was not standardized and probably was erroneous."
While that information has not been
disseminated widely, he says, it is in the
possession of the induced seismicity
work group, which will be meeting again
this fall.
Meanwhile, he points out, the frequency
of earthquakes has diminished substantially
from the 2015-16 occurrences that prompted
the KCC to issue orders capping injection
volumes in a five-county area in SouthCentral Kansas, as is the volume of water
being disposed in wells identified.
Cross reports total seismic activity
registered a 63% decline from 2015 to
2018, while felt seismic activity in Kansas
dropped 39% between 2017 and 2018.
Federal Legislation
At the same time these state-level
efforts have been ongoing, Cross says,
KIOGA also has been tracking and working
on a variety of federal initiatives important
to Kansas operators. During a June visit
to Washington, Cross reports, he visited
with 21 lawmakers, Secretary of State
Mike Pompeo, White House staffers and
a number of federal agency heads.
Legislative issues Cross says he discussed range from climate change, carbon
taxes and the Green New Deal to legislation on pipeline safety and federal oversight of hydraulic fracturing. On that last
item, he points to the Safe Hydration is
an American Right in Energy Development
(SHARED) Act, introduced July 1 by
Representative Jan Schakowsky, D-Il.
Schakowsky describes the SHARED
Act as "part of the 'Frack Pack' of bills
to improve safeguards against the dangers
of hydraulic fracturing." The SHARED
Act would require testing of water sources
near fracturing operations and public disclosure of the results.
"Congresswoman Schakowsky is
pulling out the tired old, debunked arguments from environmental activists in
the past," Cross summarizes. "The fact
is, more than two dozen scientific, peerreviewed studies published since 2010
conclude hydraulic fracturing is not a
threat to groundwater."
Opining that the fracturing bills are
not likely to advance beyond the House
of Representatives, Cross emphasizes
the importance of face-to-face meetings
with lawmakers. "I always follow those
meetings with written materials because
they need to see the information and

then see us multiple times during the
year," he says.
Methane Emissions
At the top of KIOGA's federal priorities
list, Cross indicates, are the Environmental
Protection Agency's ongoing efforts to
rewrite the New Source Performance
Standards under the Clean Air Act Subpart
OOOOa (40 CFR, Part 60) for oil field
emissions of methane and volatile organic
compounds released in 2016 during the
Obama administration.
In September, the Trump EPA proposed
lighter-handed regulation of methane
emissions that still did not deal satisfactorily with marginal wells (AOGR, October
2018, pg. 26).
Cross says he met with EPA Administrator Andrew Wheeler on June 19. "He
seemed to have a very good understanding
of the issues important for Kansas producers and underscored his focus on carrying out President Trump's deregulatory
agenda," Cross reports.
KIOGA submitted comments to EPA
last December detailing the economic
and scientific impact of methane regulations on marginal wells in Kansas, Cross
says, and also participated in comments
filed at that time and again on June 17 by
the "Independent Producer Group (IPC),"
led by the Independent Petroleum Association of America.
Those latter comments, Cross notes,

rebut a number of inaccurate points made
in comments by the Joint Environmental
Coalition, whose members, IPC points
out, "are advocates for the termination
of American fossil energy production."
In its comments, IPC emphasizes that
while Quad Oa addresses new and modified emission sources, because it applies
to methane, which is a noncriteria, nonhazardous chemical, it will trigger a nationwide regulatory requirement for existing oil and gas production facilities
under Section 111(d), thereby threatening
the economic viability of approximately
770,000 low-production oil and gas wells
across the country.
While IPC's June comments touch on
alternative means of limiting emissions
to meet state equivalency standards for
Quad Oa's provisions for fugitive emission
leak detection and repair, they spend a
great deal of time rebutting inaccurate
data on marginal well emissions drawn
from a report released by the Environmental Defense Fund.
Among the errors in EDF's report, IPC
says, is that it charts methane emissions as
a percentage of production rather than on a
volumetric basis. "Thus," the comments
state, "1 Mcf emitted out of 10 Mcf produced
is (reported as) 10%, but 50 Mcf emitted
out of 1 million cubic feet produced is 5%.
As a result, it skews the perception of the
data to imply that low-producing wells are
large emitters when they are not."
Additionally, IPC says, EDF calculated

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