DERRICK DOCKET: PIOGA SUBMITS COMMENT TO DEP IN OPPOSITION OF PROPOSED CRIPPLING STATE PLAN

Todd Papasergi, PIOGA General Counsel & Vice President of Government Affairs

Without any formal rulemaking or independent oversight, PA DEP intends to implement new emissions equipment and monitoring standards only on the oil and gas industry that will turn Pennsylvania from an energy leader to an energy nightmare.

Through oral testimony given by PIOGA's President and Executive Director Dan Weaver and a written comment prepared by PIOGA's General Counsel Todd Pappasergiand Mr. Weaver, PIOGA continued its industry leading charge against the proposed state plan by the PA Department of Environmental Protection to implement methane reduction regulations for existing oil and gas facilities in the Commonwealth.

While recognizing that methane reduction in any form, whether from agricultural, industrial, or even naturally occurring sources, would have a positive effect on the environment, PIOGA strongly objects to the proposed state plan. As Mr. Weaver stated in his testimony, the plan as proposed "will obliterate Pennsylvania's status as a global leader in energy production, have crippling economic consequences, and endanger public safety" in a far greater way than any potential methane emission reduction that may occur under these new rules. Even more concerning, DEP intends to impose these multi-billion dollar requirements on the industry without any formal rulemaking, statutorily required independent oversight, or consideration of the vast differences between the different sectors of Pennsylvania's oil and gas industry.

Under the proposed state plan, any oil and gas facility constructed or modified prior to December 6, 2023 will need to be retrofitted with new equipment and the operators of those facilities will also be required to implement labor-intensive and cost-prohibitive emissions monitoring. Pennsylvania's oil and gas operators could now be faced with an impossible choice: either spend crippling amounts of money on equipment and labor costs or risk not receiving a new air quality permit to operate in the Commonwealth. The conventional natural gas industry alone could face upwards of $325 million annually just in monitoring costs.

To lessen this unconscionable burden on the industry, PIOGA has proposed important modifications to DEP through its testimony and comment:

• Conduct economic-based remaining life (RULOF) analysis on various classes of oil and gas facilities;
• Develop tailored and cost-effective solutions for low-production and marginal well sites;
• Pause further development of the state plan in coordination with the U.S. EPA's recent announcement for extensions on methane emission compliance;
• Take advantage of these extensions to conduct a full and formal rulemaking process for methane regulation; and
• Consider expected new data and guidance from EPA that will create a more balanced regulatory program.

As Mr. Weaver has stated before, now is the time for action and involvement.Not a PIOGA member but want to get involved? Learn more about the benefits of PIOGA membership, such as having direct input on important issues such as these, by visiting PIOGA's membership page!

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