American Oil and Gas Reporter - August 2022 - 43

as more prolific ones can instantly render
marginal wells uneconomic, he observes.
" Rather than seeing the occasional weather-related
interruption, you are going to
lose those facilities year-round, " Modglin
warns. " The state benefits far more from
a well maintaining production year-round
than from ensuring that a storm will not
interrupt it a couple days a year. "
" There must be a balance of promoting
reliability without hurting operators'
ability to make a profit, " Alliance Chairman
Houston Sullivan emphasizes. " The goal
must be promoting reliability in a prudent
way that does not unnecessarily force
weatherization investments on wells that
cannot justify it. "
According to Sullivan, co-chief executive
officer at Veritas Permian III, the Alliance
has worked to convey that point to the
Texas Railroad Commission and the Electric
Reliability Commission of Texas. " There
have been many conversations about how
to thread that needle, " he assures. " I think
they have been constructive. "
" We have been working closely with
the RRC to figure out how to prevent
new requirements from cutting overall
gas production, " Modglin relates. " The
commission has been sincere about
trying to work through that, but it is resulting
in a lot of weatherization paperwork
for operators. "
Natural gas producers are not the only
ones to express misgivings about sweeping
implementation mandates, he continues,
citing some transmission utilities' formal
comments about the practical challenges
of suddenly designating 59,000 natural
gas facilities as critical. " That requirement
needs to be revisited, " Modglin urges.
" The minimum floor needs to be raised
from 15 Mcf a day for gas leases and 50
barrels a day for oil ones. "
A more practical minimum for critical
natural gas leases would be 250 Mcf/d,
he suggests, noting that such a threshold
corresponds with Texas' statutory definition
of a marginal producing asset.
" It is all about dry gas availability
during an emergency, so that means prioritizing
gas storage and major pipelines, "
Modglin considers. " Those facilities are
supported by major gas processing facilities
and major leases. And if an event lasts
even longer than Uri-exceeding a week-
the next tier needs focus on very large
leases with a lot of production. Even at
that point, marginal facilities do not yet
warrant a higher degree of focus. "
To improve power reliability during
emergencies, Modglin recommends encouraging
gas-fired power plants to buy
adequate supplies through firm contracts.
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AUGUST 2022 43
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American Oil and Gas Reporter - August 2022

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