American Oil and Gas Reporter - December 2021 - 34

rulemaking process would consider that
analysis, EPA released its methane proposal
before the DOE released its study.
Arrington responded by blasting the
move and introducing H.R. 5991, " The
Science-Based Emissions Standards Act
of 2021. " " Instead of emission standards
based on science provided by the DOE,
President Biden made a rash and arbitrary
decision to appease climate alarmists departing
from longstanding cost/benefit
analysis that protects smaller, independent
energy producers from burdensome regulation, "
Arrington asserted. " 'The ScienceBased
Emissions Standards Act of 2021'
will force the EPA to slow down a rushed
process and ensure the best and most
current data available is considered when
developing methane regulations that have
a major impact on American energy. "
Fuller points out that the DOE report
is scheduled to come out before the comment
period on the methane rule closes.
" There probably will be a window of time
to evaluate DOE's report before the comment
period closes and clearly it should
be out in time for the second proposal, "
he acknowledges. " However, releasing the
rule before the study is still problematic. "
He explains that DOE's study should
shed important light on some key questions.
" Do marginal wells have emissions
associated with their pneumatic controllers? "
Fuller poses. " Do you need to
replace pneumatic controllers on lowproduction
wells? In other words, is a
pneumatic controller a realistic emissions
source in all operations, or merely an
emissions source at a site with 20 hydraulicly
fractured wells, but not at a site
with one or two conventional wells producing
a couple barrels of oil a day? "
Fuller says available information suggests
small wells' process equipment produces
little or no methane or VOC emissions.
" Will EPA force operators to replace
pneumatic controllers with no emissions? "
he asks. " We would rather EPA staff have
information about what is really happening
with emissions at low production wells,
instead of trying to shoehorn the information
into the regulatory evaluation after
EPA already has framed a structure. It is
better if EPA starts from a fresh piece of
paper instead of needing us to convince
it to pull back from what it has spent two
years developing. "
Fuller adds that EPA seeks to redirect
regulatory language away from any assumption
that low-production wells equal
low-emission facilities. At the same time,
it is moving its rules model to oversee
facilities less at the individual well level,
but with a more compound approach,
such as setting thresholds for tank batteries
instead of individual tanks.
" However, because those evaluations
involve the use of Subpart W emissions
factors, it raises questions about the
Industry Advocates React To Biden Administration's Proposed Methane Rule
Editor's Note: Along with numerous policymakers and political
analysts, many oil and gas representatives issued statements
about the U.S. Environmental Protection Agency's proposed
methane rule. The following is a sampling of those responses.
" As PBPA continues to review the nearly 600-page proposal
and the more than 200-page regulatory impact statement of the
rule, we are concerned this approach continues to put political
posturing ahead of sensible policy. This proposal, offered at an
environmental conference where thousands of representatives
flew to Glasgow, where the world's largest polluters (China,
India and Russia) didn't even attend, is another affront to
Americans paying more and more to live their daily lives. "
- " The Standard " from the
Permian Basin Petroleum Association
" As written, this proposal will increase the costs of domestic
production and, in many cases, end the economic life of tens
of thousands of marginal wells much sooner. This would put
hundreds of small businesses and thousands of employees at
risk, reducing supply and depriving Americans of needed
natural gas during peak demand. We have urged EPA to take
into account the actual risk from low production wells and
wait until DOE reports its findings, which are due to be
published very soon. "
-Texas Alliance of Energy Producers
President Jason Modglin
" TIPRO will continue to engage with the EPA on this important
issue as we more thoroughly review the proposed methane rulemaking.
These regulations could disproportionately impact
smaller U.S. oil and natural gas producers, who do not have the
same financial wherewithal, resources or often the internal regulatory
expertise as larger producers.
" We look forward to working with the EPA to minimize the
impact of these regulations of these regulations on smaller
producers, particularly as other measures are being considered
34 THE AMERICAN OIL & GAS REPORTER
" We support the direct regulation of methane from new and
existing sources and are committed to building on the progress
we have achieved in reducing methane emissions. EPA has released
a sweeping proposal, and we look forward to reviewing
it in its entirety. We will continue working with the agency to
help shape a final rule that is effective, feasible and designed
to encourage further innovation. "
-Franch Macchiarola, senior vice president for policy,
American Petroleum Institute
" IPAA recognizes the need for environmentally sound, costeffective
regulations to manage emissions. There is consensus
among companies, small and large, on the importance of reducing
emissions, and new breakthrough technologies have
been developed to more cost-effectively and efficiently
monitor and measure emissions. IPAA is encouraged by its
initial analysis of EPA's proposed regulations-the agency
has tried to be responsive to our concerns for improved
cost-effective monitoring technology and recognizing the
importance of addressing small business challenges. "
-Independent Petroleum Association of America President
and Chief Executive Officer Barry Russell
at the federal level, including a disastrous tax on natural gas in
Congress' reconciliation package that would cripple small
Texas oil and gas operators and severely burden American
taxpayers. This punitive tax would result in the loss of tens of
thousands of direct U.S. oil and gas jobs, increase household
energy bills and make our country more reliant on foreign
sources of energy. "
- Texas Independent Producers & Royalty Owners
Association President Ed Longanecker
" The methane regulations proposed by EPA will likely result
in significant new costs associated with compliance. "
-Anne Bradbury, chief executive officer,
American Exploration & Production Council
American Oil and Gas Reporter - December 2021

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