Testimony by President Jason Modglin at a Railroad Commission Hearing

June 16, 2020

Chairman Christian, Commissioner Craddick and Commissioner Sitton—

Thank you for the opportunity to provide comments today regarding flaring and venting.

The Texas Alliance of Energy Producers represents nearly 3,000 individuals and member companies from across Texas with a focus on independent operators. From small family-owned businesses to large publicly traded companies, they are committed to advancing the standards of the domestic oil and gas industry.

It is an honor to be with you.

The Alliance participates in the Texas Methane and Flaring Coalition and supports its goals. We know these recommendations represent a good starting point for dialogue to continue with you and other stakeholders to show reductions in the number, duration and frequency of events.

We have made progress but there is more work to do.

The Alliance stands ready to assist the Commission with developing tools to compile and analyze flaring and venting data to improve transparency and allow for the public, and industry to better understand and prioritize the areas to improve. The Mainframe Transformation project along with continued improvements to the website, putting more forms online, and publicly accessible data will create efficiencies that benefit the commission, operators, and the public.

The Coalition report builds on industry best practices to find alternative solutions to venting or flaring during exploration and production activities.

Technology utilization and better planning practices help achieve reductions, but one of the most important tools is more pipeline infrastructure in the field to reduce congestion and capacity issues.

A one-size-fits all approach to this issue does not work for all operators or all fields and we believe the proposed matrix does a good job of providing flexibility for these operational realities. As new pipelines are built and gas processing facilities come online, there will be more opportunities to move this gas to market, which your leadership to provide regulatory certainty makes possible.  

You along with commission staff should be applauded for the incredible work you all are engaged in during the ongoing response to COVID-19. Staff continue to inspect wells; process permits and review applications timely and the Alliance is grateful for their service.

Your encouragement to find ways to open back up to allow for economic activity to resume is essential. Thank you for the recent work to reopen alternative fuels testing and the reopening of central records which is critical to industry acquisition and exploration activities.

The industry and the public have greatly benefited from robust permitting, compliance, and enforcement actions by the Commission. The policies implemented at the Commission have worked to shorten the duration and volume of flaring, limit venting extensions, and deploy new technology to the field, like drones, to increase the efficiency of inspectors.

The Alliance supports the Commission’s continued action to further monitoring and enforcement abilities and your efforts related to Statewide Rule 32.

Thank you again Mr. Chairman, on behalf of the Texas Alliance of Energy Producers, for the invitation and opportunity to provide comments.