Alliance Presents Comments to EPA Small Business Advocacy Review on Methane Proposal

Ms. Wiggins:

Thank you for the opportunity to provide written comments to the “Pre-Panel Outreach Meeting” conducted by EPA on the rulemaking, “Oil and Natural Gas Sector New Source Performance Standards,” on Tuesday, June 29, 2021. I sincerely appreciate EPA’s invitation to participate, and the information provided to participants to evaluate potential rule changes and the process for their amendment.

The Texas Alliance of Energy Producers represents over 2,600 individuals and member companies in the upstream oil and gas industry; our members are oil and gas operators/producers, service and drilling companies, royalty owners, and a host of affiliated companies and industries in Texas and beyond. The majority of our members and board of directors work for, or own and operate small businesses as defined by the Small Business Administration.
We applaud EPA’s use of the Small Business Advocacy Review Panel to gather feedback from Small Entity Representatives to minimize negative impacts of regulation that would tilt the playing field in favor of larger corporations. This is particularly important for small businesses in the oil and gas industry who are producing a globally traded commodity. American small businesses are competing directly with international competitors, who in many cases, are operated by sovereign nations.

The cost estimates provided by EPA were helpful to guide discussions with Alliance members. In many cases, operators reported that those cost may be higher because the internal operations to adapt and conduct new regulatory requirements has been limited due to the contraction of the industry in 2020. The Alliance created and tracks a Texas upstream oil and gas economic index, and the employment data contained within indicates the loss of about 36% of direct upstream jobs in Texas in the 2019-2020 industry contraction. These limitations skew the cost estimate higher due to operators being more reliant on third-party contractors to facilitate revisions to emission controls not already required by state and federal law.

Finally, we would ask that EPA and SBA consider a forthcoming study conducted by the Department of Energy’s National Energy Technology Laboratory entitled “Quantification of Methane Emissions from Marginal (Small Producing) Oil and Gas Wells”: Project Number DE-FE0031702. The project is anticipated to end September 30, 2021 and we think the study’s finding will be beneficial to EPA in evaluating new controls for potential emissions from marginal wells.

Thank you again for the opportunity to provide comments on the Pre-Panel Outreach Meeting. The Alliance looks forward to helping EPA in the full Small Business Advocacy Review Panel process.

Sincerely,
Jason Modglin
President, Texas Alliance of Energy Producers

Click here to download pdf of letter to Lanelle Wiggins, EPA Office of Policy.