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Member Alert:
Proposed general permits for methane are devastating. Please take action!

It is extremely urgent that members of PIOGA reach out in the days ahead to contact their legislators and provide comments opposing two new general permits the state Department of Environmental Protection (DEP) has proposed to target methane emissions. General Permit 5 (GP-5) is focused on midstream operations, such as compressor stations, and General Permit 5A (GP-5A) applies directly to unconventional operations (for now, it could spread to conventional operators) and wells. If these permits are promulgated unchanged, they have the potential of creating a "moratorium by permit" in Pennsylvania. 

Provided below are a few key questions and answers about the GP-5 and GP-5A permits:

Are methane emissions increasing dramatically that would merit such a drastic measure?

Independent analysis shows that unconventional operators capture nearly 99.99 percent of the methane from wells. DEP's data states that since 2009, methane emissions from oil and gas systems have decreased 0.65%, while production has increased by 977%. This includes not just production and transmission, but also the distribution systems to homes and businesses across Pennsylvania.

Are there currently no rules in place that control emissions?

Pennsylvania already has an effective program in place to control emissions. These include the existing GP-5 and DEP technical guidance requirements, which cover midstream and well site operations, provide predictable requirements for industry and successfully minimize emissions. Facilities such as well sites that are below the permitting threshold must adhere to robust leak detection, repair and reporting requirements, and demonstrate their methane reductions to DEP.

What other industries and or sectors will be subject to these new more stringent regulations?

None. DEP's proposal unfairly targets the unconventional natural gas production and transmission industry (for now) by imposing permit conditions and standards not applicable to any other industry sector.  We are not the only industry that produces emissions, and are certainly not the highest emitters. Just one example: the Commonwealth has approximately one-half million cows and ranks 5th nationally in milk production.

The proposed GP-5 and GP-5A regulations represent a significant expansion of reporting, record keeping and monitoring standards required of no other industry and far exceed the need to verify compliance of those imposed by the Obama Administration's Environmental Protection Agency in 2016.

Regulations require a cost-benefit analysis, when will this occur?

DEP is essentially developing complex regulations through permits that are not subject to the rulemaking process as defined by the Regulatory Review Act (RRA). Because DEP has evaded the RRA and therefore the requirements therein, it has failed to outline the need for these new requirements and has refused to perform a cost-benefit analysis.

Can these permits be processed in a timely manner?

While this answer cannot be determined at this time, history tells us these permits would only further exacerbate the uncertainty and delays surrounding permitting. DEP routinely takes 8-10 months, or longer, to issue air permits, despite previous assurances that they would be reviewed and issued within 30 days. The existing GP-5 permit applications are approximately 145 pages in length when completed. Ohio, on the other hand, recently streamlined its General Permit applications to just three pages.

My company doesn't have emissions, why should I care or comment?

The cost, unreasonable standards and permitting uncertainty contained in these new and revised permits further erodes the competitiveness of the Commonwealth to attract and retain capital investment and jobs while providing little if any tangible environmental benefit.  Any service company or business supporting unconventional natural gas producers has the potential to experience negative consequences if these regulations go into effect.  It is essential that members contact their legislators and provide comments to DEP by June 5th. 


Online form at www.ahs.dep.pa.gov/eComment/

Email to ecomment@pa.gov

Department of Environmental Protection Policy Office
Rachel Carson State Office Building
P.O. Box 2063
Harrisburg, PA 17105-2063

Comment period deadline is June 5, 2017

For a sample letter to your legislator click here.

Registration opens for PIOGA's big summer event at Seven Springs
This is always among our most popular events, and you won't want to miss the 2017 edition. It's a combination of fun, networking opportunities and learning, all in a gorgeous mountain setting.

On Wednesday, June 28, in addition to golf, sporting clays, the Pig Roast and other fun activities, the Product & Equipment Roundup will provide vendors with the opportunity to showcase their wares in a relaxed, outdoor environment. New this year is Wednesday's The Power of Women in Energy Lunch. The event will feature motivational speaker Coach Monique Demonaco, author of the highly engaging book, Most People Don't Need A Therapist, They Just Need A Change.

On Thursday the 29th we will present something new in place of the usual technical conference. As our industry emerges from a difficult down cycle, we need to look at strategies other companies - both inside and outside the energy industry - have used to become successful in a changing environment. Our Operators Forum and Leadership Summit will provide just those sorts of useful stories and advice. We'll also hear from former Pittsburgh Steeler Craig Wolfley as our featured luncheon speaker.

Click here to see the full agenda, download the event brochure and register online.
DEP eSubmissions update for conventional operations
Producers now have the option to submit a select number of forms and requests associated with conventional well operations using the Department of Environmental Protection's eSubmission application. The new submissions include:
  • Well Record
  • Completion Report
  • Pre-Drill Survey Sample Results
  • Request Alternate Waste Management Practice
  • Well Logs
  • Well Site Restoration Period Extension Request
  • Well Site Restoration Report
The user guide, which has step-by-step instructions on how to use the eSubmission application, has been updated and can be found on the bottom of the Oil and Gas Electronic Submission Guides webpage, located here. If you have questions, contact Lucas Swanger, lswanger@pa.gov, 717-783-9522.
State's 2016 oil & gas report shows Marcellus production skyrocketing despite fewer wells
The Department of Environmental Protection last week unveiled its 2016 Oil & Gas Annual Report. The most visible difference in this edition was that it is in an electronic, interactive format (read the department's news release here). The report also contains some interesting news about industry and DEP activity last year. Here's what Energy In Depth culled from the report:

The Pennsylvania Department of Environmental Protection has released its annual oil and gas report, and it is chock full of great news for the Commonwealth. Not only is production skyrocketing despite a decrease in new shale well permits, the agency is finding fewer violations than in years past, even with conducting more inspections than ever. Both are a testament to the improvements in technology and operations for Pennsylvania's oil and gas industry.

DEP's report shows that the number of unconventional well permits decreased 63 percent in 2016 from the height of permitting in 2011 (from 3,560 to 1,321). Interestingly, at the same time that new permitting has decreased, overall production continues to break records. In fact, Pennsylvania trails only Texas as the second largest producer of natural gas in the country, producing 5.1 trillion cubic feet in 2016.

This is occurring for a couple reasons. Not only are well sites becoming more efficient and housing more wells on a single pad to decrease environmental impacts, companies have also continuously extended the length of the laterals of new wells over the last few years. This means that a single well can now produce more gas than ever before. <Continue reading>
Penn Brad Oil Museum's annual Yellow Dog Award recognition ceremony
The Penn Brad Oil Museum will honor Harvey L. Golubock, retired President of American Refining Group, and Paul A Philips, retired co-owner of Phillips and Dart Well Services, at its annual Yellow Dog Award Dinner on the evening of Saturday, June 10, at the Pennhills Club in Bradford.

The Yellow Dog Award was instituted to honor individuals for their outstanding leadership in the oil and gas industry and dedication to helping the Penn Brad Oil Museum preserve the history of the Bradford Oil Field and the unique culture that developed along with it. Both Golubock and Phillips are long-time directors and active supporters of the museum. To make reservations for the dinner, call 814-362-1955 or visit the museum website.



Ted Cranmer Memorial Summer Picnic and Golf Outing


Memorial Day.
The PIOGA offices will be closed next Monday, May 29, as we honor the men and women who have given their lives in the service of our nation. There will be no PIOGA eWeekly next week.

Welcome aboard, Deana! Please join us in welcoming our newest staff member, Deana McMahan, who is serving as Administrative Assistant & Committee Liaison. She can be contacted at deana@pioga.org or 724-933-7306 ext. 23.

Registration deadline for Wanango golf outing and picnic. This Friday, May 26, is the registration deadline for the June 5 Ted Cranmer Memorial Golf Outing and Summer Picnic. It's an enjoyable day of golf, good food and networking that you don't want to miss. Find out more and register here.

Upcoming Events

Need to find some resource documents that were on the legacy Members Only Area?  Click here. If prompted for a password, use pioga-13.